Swiss banking giant UBS said Wednesday it had agreed to give to American authorities the names of up to 4,450 US account holders who the Internal Revenue Service suspects of using Switzerland's vaunted banking secrecy rules to avoid paying billions of dollars in US taxes.

The announcement ends an eight-month legal battle that strained Swiss-US diplomatic ties, saw UBS agree to pay $780 million in fines, and had Swiss bankers worrying that the secrecy laws that made Zurich synonymous with wealth were under siege.

IRS Commissioner Douglas Shulman declared "the world of international taxes has drastically changed" in a conference call with reporters. In a Bloomberg TV interview, Mr. Shulman said this case shows that the IRS can and will expand its global reach to catch American tax evaders.

"We're going to have our targets set on all categories of folks," Shulman said.

He also said the US will be given access to 5,000 Swiss accounts which at one point had $18 billion in assets.

No fishing expeditions

But the agreement makes it clear that the days of the numbered Swiss account aren't over and the disclosures required by the deal aren't nearly as broad as originally expected.

In a nutshell, the Swiss have said that they will disclose names where there's strong evidence of tax evasion, but not allow fishing expeditions by the US or other foreign governments. The US had at one point said it wanted the names of 52,000 UBS clients.

UBS said in a statement that it would provide the identities of "approximately" 4,450 account holders to the Swiss tax authorities, who will then determine which of those names should be passed on to the IRS. The Swiss tax authorities' decision will also be subject to "judicial review." There are no additional fines for UBS and the deal does not require Swiss banking laws to be changed. The announcement said the disclosures are legal under the terms of a 1996 double taxation treaty between the two states.

"This agreement helps resolve one of UBS's most pressing issues,'' UBS Chairman Kaspar Villiger said in a statement. "The agreement will allow the bank to continue moving forward to rebuild its reputation through solid performance and client service. UBS welcomes the fact that the information-exchange objectives of the settlement can be achieved in a lawful manner under the existing treaty framework between Switzerland and the United States."

Two Swiss newspapers reported last weekend that the targeted UBS clients face up to $3.7 billion in back taxes and penalties.

But while Mr. Villiger put on a brave face, some are wondering if the Swiss banking industry will suffer after the disclosures.

Tarnished reputation

Bruce Zagaris, a tax lawyer who represents several UBS clients, said the Swiss reputation for secrecy has "absolutely" been tarnished. Mr. Zagaris said that the Swiss prize their ability to protect customers from the prying eyes of other governments but that this situation has shown that, when faced with legal action, the Swiss, will give up select information.

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