UBS vs the IRS

UBS AG, which is the largest Swiss bank by assets is being sued by the US Government. In an article from Bloomberg.com dated July 13, David Voreacos reports on the matter.
This case, which is a very complex has set some feuds on the Swiss Government as well as the US Government. The situation is this, the US Government is accusing UBS of facilitating tax fraud by top Americans earners and now want the name and the accounts of those accounts holders. On the other end UBS has to violate Swiss criminal laws of protecting bank secrecy by giving out those names and accounts.
At this point the bank is trying to settle out of court, discussion has been undertaken by the Swiss Government and the US Government. The US sued UBS on February 19 and UBS agreed to pay $780 million to "defer prosecution for helping wealthy Americans evade taxes".
The US Government even intend to seized UBS assets that are in the US if they do not comply with their request.
This case is very delicate, because it is about two laws that have been broken. Swiss law recognizes tax fraud and not tax evasion as a crime. The IRS law recognizes tax fraud as well as tax evasion as a crime. Any settlement would force the Swiss law to change or either the US law to change when it comes to tax fraud.
UBS has admitted helped Americans evade US taxes by opening accounts in tax havens, and making the beneficiary of those accounts non existent companies.
As it is said in the article it would be best for UBS to settle out of court especially that those fraud were made on US soil. Judge Skarlatos who is in charge of this case said in the article," Swiss laws don't apply when you actively violate the laws of the United States". If the bank does not want to see all its assets that are in the US being seized they will be better off giving out those names.