Many of the inquiries, which are being handled by dozens of prosecutors around the country, will result in criminal complaints, said this person, who was not authorized to speak publicly, NYT also said.
Apparently, it's a dollar amount thing. NYT continues:
A second person close to the matter who also was not authorized to speak for attribution said the criteria included clients who set up offshore entities to evade taxes and those who had contact with Swiss-based UBS bankers, in person, by telephone or by e-mail. Accounts over a certain dollar amount will be included.
The Internal Revenue Service plans to release the criteria next week, but the dollar threshold will not be publicly disclosed, these two people said. The authorities do not want UBS clients whose accounts fall below the threshold to think that they might avoid investigation, the first person said.
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