A federal judge Monday agreed to postpone a hearing on whether Swiss banking giant UBS must turn over the names of 52,000 clients with $14.8 billion in secret offshore bank accounts to allow the U.S. and Swiss governments more time to resolve the dispute.
The federal government and Zurich-based UBS jointly requested the delay, saying the Swiss and U.S. governments are trying to settle the high-profile case.
The Internal Revenue Service has justified its demand for the sensitive information based in part on UBS' own admission that the bank helped wealthy American clients set up accounts offshore to dodge income taxes.
In the confrontation, the United States is seeking to trample on long-standing principles of Swiss banking secrecy, which lie at the heart of Switzerland's large and lucrative financial-services industry.
The Swiss government contends that UBS would break Swiss law if it complied with a wide-ranging IRS summons.
The Justice Department said the parties have agreed that any settlement would "include a provision requiring UBS to provide the IRS information on a significant number of individuals with UBS accounts." It added: "If an alternative resolution is not reached, the Department of Justice will continue to vigorously pursue enforcement of the summons through the court."
Judge Alan S. Gold set a hearing for Aug. 3 and 4 if the parties don't reach a settlement or request more time. He told the attorneys to provide a telephone update on the talks on July 29. The case is already netting big payoffs for the IRS, which is wielding both carrot and stick. Many U.S. taxpayers with secret offshore accounts at UBS and elsewhere have been rushing to make voluntary disclosures to the IRS and paying back taxes, interest and civil fines to deflect criminal charges, tax experts say. The IRS has set a Sept. 23 deadline for such voluntary disclosures.
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