I'm looking for an attorney who is experienced in swiss banking secrecy; that is to say, someone who can set up a private trust so that assets may not be traced to an american beneficial owner.

The amounts involved are small but substantial (slightly lower than the typical $2M needed to make the expense of a trust worthwhile).

Ideally this would be someone who is able to challenge UBS (or at least fire off a letter of warning) should they decide to comply with the IRS's order to turn over the names of their clients from 2002-2007. However, as I understand it once the EBK makes this decision it is a matter for the criminal courts rather than the civil ones, so this is a long shot. However, the attorney should be knowledgeable enough to explain why this is a bad idea.

I have already retained a US tax attorney to help with the declaration of overseas assets and the filing of amended returns; the issue now is what to do with the money should I decide not to repatriate it. It's not enough money to go to Singapore, and Panama is too sketchy. For obvious reasons Luxembourg and Isle of Man are right out.

Which EBK decision do you refer to?
Why are Luxembourg and Isle of Man unsuitable?
What about Channel Islands or British Virgin?

How about Delaware?

If you are worried about UBS turning over historic data then setting up a trust now won't necessarily help.

Turn it in to diamonds & I'll wear it!

I just talked about things like that with one friend of mine and he mentioned two good lawyers. One is in Zug and the other one is in Zurich.
If you would like to check out those guys - PM me and I will forward you their phone numbers.
Wish you all the best.

I believe he is referring to the decision by the EBK to break the banking secrecy laws; it happens occasionally, witness the pending decision of the swiss courts concerning the Miami subpoenas issued to UBS. For the record I'm not sure if this decision is made by a swiss court or by the EBK.
Banking secrecy in the British Commonwealth is not suitable for US clients, in my opinion. Using a trust helps, but for private clients with personal accounts there is not enough protection.

As to the original poster, trying to sue UBS will be a fool's errand and I doubt any barrister will entertain the idea.

I doubt that the EBK can or would make such a specific decision pertaining to an individual. Even if the EBK did such micro-management, the individual can challenge that administrative decision in a Swiss court and appeal it all the way to the Supreme Court.