cite please!
The actual agreement between the IRS and the Swiss government is here:
www.irs.gov/pub/irs-drop/us-swiss_government_agreement.pdf
As explained in this Forbes article,
http://www.forbes.com/2009/08/19/ubs-irs-taxes-business-beltway-ubs.html
“The agreement is the latest chapter in a year-long attempt by the IRS to go after tax evaders with Swiss bank accounts at UBS. In February, UBS agreed to pay $780 million to avoid criminal prosecution for its activities in the U.S. promoting the hidden accounts.”