Did the IRS Really Win Case Against UBS?

The IRS settled its summons case against UBS this week and will get account information for fewer than 5,000 Americans with accounts at the Swiss bank. Since the IRS was originally asking for information on 52,000 accounts, is this really the victory the IRS claims it is?

Although the settlement agreement apparently lets the IRS pick which accounts are disclosed (so the IRS won't get information it already has perhaps?) it seems a stretch to think that 45,000 or more secret account holders have come forward under the IRS's "amnesty" program or that the IRS has been able to get that much information from the individuals who have already pleaded guilty ot tax evasion. While the banker has given up a number of names, it is doubtful that he had access to over 45,000 accounts - so what about the other 47,000 tax evaders?

Also, the settlement allows UBS to notify account holders and lets them appeal their account's disclosure to the Swiss government. Are the Swiss using this as a way out?

Meanwhile the attack on offshore accounts continues with more indictments this week.

IRS Settles UBS Summons Case

It looks like the Swiss backed down and have agreed to let UBS reveal the names of U.S. tax cheats with accounts in the Swiss bank. While the IRS was originally after information about 52,000 accounts, they likely settled for a lot less. Most media outlets are reporting that information about 5,000 to 10,000 accounts will be disclosed.

Also unknown is whether those disclosures will include information about individuals who have already taken advantage of the IRS's amnesty program, or if the IRS will get new names.

In the meantime, this week another individual pled guilty to keeping an offshore account at UBS.

Will prosecutions pick up once the amnesty program ends?