How UBS chooses the names it will give the IRS
Lynnley Browning looks today at the 4,450 clients that UBS is going to give up to the IRS, going down the list of characteristics that UBS is going to look for when deciding which of its accounts to choose.
What’s interesting is that it looks as though more than 10,000 UBS clients have already approached the IRS voluntarily. Clearly if client focus is UBS’s number-one priority (as all banks always say that it is), UBS will have every incentive to try to pick a subset of that group when it hands over the 4,450 names. And given how close UBS private bankers are to their clients, I’m sure that UBS knows which of its clients have chosen the voluntary-disclosure route.
There’s no obvious way that the US government can force UBS to give up a certain number of names the IRS doesn’t already have. After all, it can hardly complain if UBS told some of its clients that they were probably going to be given up anyway, so they should probably hand themselves in voluntarily.
But it will still be interesting to see whether UBS ends up handing over to the US government any information that the IRS hasn’t already been given voluntarily. My guess is that of the 4,450 names, only a tiny fraction will be unknown to the IRS at this point.