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The United States is drafting legal documents that seek to force nearly a dozen Swiss banks and international banks with Swiss branches to disclose the identities of American clients evading billions of dollars in taxes, sources briefed on the matter said.
The drafting of the documents - grand jury subpoenas and broad requests known as John Doe summonses - is a fresh US shot across the bow at Switzerland and its battered tradition of bank secrecy. The Alpine country, a noted tax haven that is the global capital of offshore private banking, has been under attack from US Justice Department and Internal Revenue Service officials conducting a broad criminal investigation into private banking services that US authorities say enabled wealthy Americans to evade billions of dollars in taxes.
The documents could be served within a month or so on 10 banks, including some with headquarters outside Switzerland, these persons said. Charles Miller, a Justice Department spokesman, declined to comment. The legal pressure signals a new front in Washington's fight against Swiss bank secrecy, a battle that in recent years has resulted in scores of Swiss bankers and advisers being charged, dozens of American clients indicted and several large banks investigated.

Copyright Reuters, 2011

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