Will UBS name names as part of an ongoing investigation into its offshore accounts? Maybe.

The Times is reporting that UBS may reveal the names of up to 20,000 of its American clients as part of the investigation into alleged “tax irregularities.” A spokesman for UBS has, of course, declined to comment.

The US government believes that private bankers at the Swiss headquartered UBS may have helped American clients hide as much as $20 billion in offshore accounts to avoid paying tax. The cost to US taxpayers for the scams? $300 million in lost taxes.

UBS has been under investigation by the US government since May. The bank has indicated that it will cooperate with US officials. Specifically targeted are private bankers in the “wealth management division”.

At least one criminal plea is expected: last week, Bradley Birkenfield, a former director at UBS, indicated that he intends to plead guilty to a single charge of conspiring to defraud the United States. Mr. Birkenfield faces up to five years in prison. He had previously pleaded not guilty to charges that he helped billionaire investor Igor Olenicoff hide $200 million from US tax authorities. Olenicoff, worth an estimated $1.6 billion has already pleaded guilty to tax charges and has agreed to pay $52 million in back taxes, plus penalties and interest.

Olenicoff also received two years probation and must perform 120 hours of community service; the light-ish sentence lead insiders to believe that Olenicoff told authorities what he knew as part of a deal.

Will UBS follow suit? Is Olenicoff just the tip of the very public iceberg?

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Kelly Erb is a tax attorney, tax writer and podcaster.

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