A few other notable quotes from the article are:
Early on, Justice Department prosecutors viewed UBS as a "stalking horse" case, which they could use to prod other banks to drop their business of helping rich Americans hide income from the IRS, according to people close to the case.With regard to the use of the UBS Settlement as a blueprint or template for obtaining similar information from other banks, see my prior blog here discussing the interpretation of the double tax treaty which is not specific to UBS. And, I suspect that banks in other European tax havens will be swept in also, perhaps with similar or analogous interpretations of the treaties.
In the process, government officials hoped they could induce alleged tax evaders to come forward to pay their taxes and provide information about bankers, accountants and others who helped them set up their offshore accounts.
Lawyers following the UBS settlement now are watching to see whether the settlement establishes a blueprint for how the IRS can obtain information in the future from Swiss banks.