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No One Expects The Spanish Inquisition!

Face it. There is no escape and you banks are so unpopular now that any hope you had at generating sympathy is gone gone gone. We want to know your customers. We want to know when you knew them. We want to know how you met them. We want to know who they know that you know. Brace yourself. This might be a bit uncomfortable.

The U.S. Internal Revenue Service (IRS) is preparing to pursue other foreign banks for allegedly facilitating tax evasion by wealthy Americans following its high-profile case against Switzerland's UBS, an IRS official said on Monday.
UBS, Switzerland's largest bank, in February acknowledged that it helped U.S. clients conceal assets from the U.S. government. It agreed to pay a $780 million fine and identify some of its American clients.

Meanwhile, don't think we don't see you, UBS, over there in the corner trying to get the United States to just drop the whole thing and let you gently set your clients adrift before Switzerland signs a new tax treaty with the United States to address the problem going forward (i.e. after you've moved the biggest clients to offshore subsidiary asset managers).
IRS says set to pursue "other banks" on tax evasion [Reuters]