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In Tax Deal, Some Swiss Banks Opt for Tougher Plan if It Means Less Legal Trouble

By Colby Adams

As a long-negotiated U.S.-Swiss tax settlement inches forward, some banks in Switzerland are asking themselves an unlikely question: can we disclose more? Under an agreement reached in August, Swiss banks not already under investigation by the U.S. Justice Department for their alleged role in aiding American tax evaders had until last month to identify themselves as "Category 2 Banks," a distinction that will allow them to avoid prosecution in exchange for paying a fine and sharing sensitive data. The deadline is not the last for Swiss banks this year. Those identifying themselves as "Category 3" or "Category 4" banks-financial institutions...

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