One for the tax geeks. One of the reasons there may be a stand off between the IRS , the Swiss government and UBS is the US-Switzerland tax treaty which has the following paagraph in Article 26 Exchange of Information.
3. In no case shall the provisions of this Article be construed so as to impose upon either of the Contracting States the obligation to carry out administrative measures at variance with the regulations and practice of either Contracting State or which would be contrary to its sovereignty, security or public policy or to supply particulars which are not procurable under its own legislation or that of the State making application.
I guess that means that if and to the extent that Swiss law requires a bank not to disclose any information, then they don't have to under the tax treaty, whatever the US courts or government say. There may be bona fide case to answer for each of the 52,000 names referred to by the IRS, but without all the paperwork suggesting tax fraud for each of those names, the Swiss government is not going to concede.