About 500 families may have a little bit less to be thankful for this morning: Swiss tax authorities have announced that they have notified the first UBS 500 clients whose names will be turned over to US government officials.

The 500 clients are the first of 4,450 names to be released under an agreement reached in August. The Swiss have one year to release all of the names.

Those taxpayers whose names have been selected have 30 days to appeal to Switzerland’s administrative court. Um, good luck with that. Part of the criteria for determining whether to turn over the names involved instances of “clear fraudulent actions” including the production of false documents. I’m not sure you could argue your way out of that one – even in Switzerland.

Of course, other criteria apply and the Swiss are picking over the accounts with a fine toothed comb. My strong bet is that those whose names are released (remember, we’re talking 4,450 out of more than 52,000 account holders) have already met a pretty significant threshold and that appeals will be difficult at best.

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Kelly Erb is a tax attorney and tax writer.

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