Those Conservative Americans would rather die than move their corporate headquarters to, say, Dubai, or the Cayman Islands or pull any of those other cheap tricks meant to avoid being loyal to the hands that feed them.

"The number of clients the authorities are seeking to identify is far higher than previously believed, raising new questions about the scale of UBS’s activities and the number of Americans who could be snared in the investigation. Federal authorities initially focused on 19,000 accounts, and UBS turned over about 250 names on Wednesday. That figure now seems certain to grow.

"The court document alone dealt a stinging blow to UBS, whose corps of private bankers discreetly tend the fortunes of billionaires and multimillionaires. Filed in a Miami court, the papers provide a rare inside look at the secretive ways of Swiss banking.

"The 2004 memorandum, for instance, described how UBS created hundreds of “dummy” offshore corporations where its clients could hide money from the I.R.S. An e-mail message sent that year captured some of the coded language used by UBS bankers. In their world, “one nut” meant $250,000, while “one swan” meant $1 million. Colors were used to designate certain currencies. Orange, for example, represented the euro; blue, the British pound. Several messages described UBS actively referring clients to outside lawyers and accountants in Switzerland and elsewhere who set up secret accounts for them."