Pick a dictator, almost any dictator - Cuba's Fulgencio Batista, the Philippines' Ferdinand Marcos, Haiti's Papa and Baby Doc Duvalier, the Shah of Iran, Central African Republic Emperor Jean-BÉdel Bokassa - and they all have this in common: they allegedly stashed their loot in secret, numbered accounts in Swiss banks, safely guarded by the so-called Gnomes of Zurich. This association - of bank secrecy and crime - has been fed into the public's imagination by dozens of books and movies. It's a reputation that rankles the Swiss, who have a more benevolent view of their commitment to privacy - one that happens to extend to tax privacy. Don't ask, because we won't tell.
But the dramatic federal investigation of Switzerland's UBS has blown the lid off bank secrecy - and revealed how Swiss banks abet tax evasion on a far more widespread, if more banal, level. Over the past two decades, these secret banking services have been peddled progressively downmarket - first to the lesser-known fabulously wealthy, then to just the wealthy; more recently, private bankers have been tripping over themselves soliciting business from doctors, lawyers and other folks who are what the biz generally calls "high net worth" individuals. "The IRS has been concerned for decades that a combination of a global economy, the Internet, offshore banking, was really going to take offshore tax evasion from the old so-called 'gentlemen's sport' to tax evasion for the masses," says Mark Matthews, a former deputy IRS commissioner and now a tax attorney with Morgan, Lewis & Bockius LLP.
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