SCENARIOS-UBS seen paying big to settle U.S. tax row
* Media reports talk of billions of francs
* Settlement could precede hearing on July 13
* Further client name disclosures expected
ZURICH, June 29 (Reuters) - Swiss bank UBS (UBSN.VX) (UBS.N) is expected to agree to a huge payment to end a tax row with the U.S. that dented its reputation even as it struggled with heavy losses from the global financial crisis.
U.S. tax authorities, which accuse UBS of helping rich Americans avoid paying taxes, have asked UBS to disclose details of about 52,000 secret Swiss accounts, and Swiss media say UBS could pay billions of dollars to settle the case. [ID:nLS407218]
A settlement would be the second deal cut by UBS with Washington after it agreed in February to pay $780 million and to release about 250 names of U.S. clients to avert criminal charges. [ID:nLJ194661]
The U.S. Internal Revenue Service (IRS) and U.S. Department of Justice have until the end of Tuesday, June 30, to submit an opinion in the case ahead of a court hearing on July 13.
UBS declined to comment on the possibility of a settlement.
WILL UBS PAY A FINE?
Yes, if it settles. Swiss newspaper Sonntag said on Sunday UBS would pay between 3 billion and 5 billion Swiss francs ($2.76 billion to $4.6 billion) to close the tax litigation. UBS has declined to comment on the amount.
Lawyers say the U.S. administration is determined to chase tax cheats and will hit UBS hard to discourage others. But some observers say too large a fine could prompt Swiss cantons to reject a broader U.S.-Swiss tax deal sealed earlier this month. "If there is huge negative publicity, there would be a high risk that the double-tax treaty would fail, which is not in the interest of Switzerland and the U.S.," says Sarasin analyst Rainer Skierka.
HOW QUICKLY WILL UBS SETTLE?
Analysts say a settlement could come before the hearing on July 13.
"If the U.S. can prove UBS marketed hard on U.S. citizens being able to dodge taxes, a settlement before July 13 is likely," said Evan Stewart, partner at U.S. law firm Zuckerman Spaeder.
"But if they settle before July 13, the settlement will be very one-sided in favour of the U.S. government."
But another lawyer who advises a U.S. client of UBS said there were still many unresolved issues, which pointed to a later deal.
The settlement will most likely include the transfer of the names of relevant clients to U.S. tax authorities.
The Neue Zuercher Zeitung, Switzerland's leading newspaper, said the IRS already holds more than 10,000 names of UBS's U.S. clients. If UBS encourages clients to turn to the IRS for voluntary tax disclosure, this might result in a more lenient deal, lawers said.
WHAT ARE THE IMPLICATIONS FOR BANKING SECRECY?
The U.S. litigation against UBS is part of a global clampdown on tax evasion.
Lawyers and tax experts say the U.S. administration will not stop at UBS but will continue to push other foreign banks to ensure their U.S. clients pay the taxes they owe.
Lawyers also expect European nations to follow suit.
"The UBS lawsuit is just an intermediary step in a trend towards automatic exchange of tax information," said a Swiss-based lawyer who has advised U.S. clients of UBS.
"It's a matter of time, and that will be the case in other countries and all over the world."
WILL A SETTLEMENT END UBS'S U.S. WOES?
Putting the tax issue aside would be a huge relief for the troubled bank, but lawyers do not rule out the possibility of clients claiming damages in the United States, something that is not allowed under Swiss law.
(Reporting by Lisa Jucca and Jason Rhodes, editing by Will Waterman)








