Are you ready for this? No, are you REALLY ready for this? Everything you know about this Zurich bank is about to change, as it pushes forward with some unabashed house-cleaning. They are not just dusting off the carpets, they are gutting the ballroom. After writing down more than $37 billion of mortgage-old socks-oil drum-what-have-you-related securities, they are now looking to dispel their clubby image by giving four board members the boot (this action to take place Oct. 2, when the members will reportedly step down and be replaced by new senior directors). But does turning over a fresh leaf mean the bank is ready to face its biggest monster under the bed yet?

A U.S. legal action that would force Swiss bank UBS AG to reveal the names of American customers with secret accounts may prompt some to pay back taxes rather than risk a criminal investigation by the Internal Revenue Service.

Federal prosecutors took the unprecedented step yesterday of asking a Miami federal judge to let the IRS issue a summons to Zurich-based UBS for the information. Earlier last month, former UBS private banker Bradley Birkenfeld pleaded guilty to conspiracy and said the bank helped wealthy U.S. citizens conceal $20 billion in assets and evade income tax.

The judge is likely to grant the so-called ``John Doe'' summons, said Jack Blum, a partner at Baker & Hostetler LLP and an expert on offshore banking. UBS may have little choice but to comply, he said, because the Swiss government appears to be cooperating. The summons would be the first by the U.S. against a foreign bank. UBS dropped to the lowest in almost a decade in Swiss trading.

"The bank is in a very difficult position," Blum said. "If I were advising clients, I'd tell them to come clean; the people who come clean early will probably be allowed to get off with paying the tax, the interest and the penalties. Others could very easily face criminal prosecution."

A partial amnesty in 2003 followed an investigation into debit and credit cards linked to offshore accounts that included the issuance of John Doe summonses to Visa International Inc. and American Express Co. The amnesty yielded $170 million in taxes, interest and penalties from 1,300 people.

John DiCicco, deputy assistant attorney general in the Justice Department's tax division, said in a statement that the U.S. has been "working cooperatively" with UBS and the Swiss government to obtain the account information.

"However, we are prepared to seek enforcement if that process is not successful," DiCicco said.

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