More possibilities re. the Swiss bank account

Brian Beutler at Talking Points Memo reports on some speculation that I offered regarding the Swiss bank account, and in particular the possibility that Romney may have needed to participate in the IRS amnesty program (which has more recently been denied, but hadn't been addressed yet when we spoke):

"Theory #2: Romney and his financial advisers lost track of the Swiss account.

"I know that sounds implausible but stay with me here....

"Daniel Shaviro ... floats this theory: What if Romney’s ... money managers simply overlooked the trivial interest he earned on this account until the federal government came knocking at UBS’ door.

“'Obviously, no one would use a Swiss bank account primarily in order to avoid U.S. tax on one’s interest income, at so low a rate of return,' Shaviro told me. 'You might have a case where the tax guys in his operation weren’t consulted on the Swiss bank account, since it wasn’t done for tax reasons, and didn’t learn about or at least prioritize it.'

“'[H]e was earning relatively trivial interest from the account. … This suggests to me that the interest may have been a side issue, and not have gotten the serious attention that he and his people no doubt gave to the [Individual Retirement Account], the Caymans entities, etcetera,' Shaviro speculates.

"Whatever Romney’s investment team may or may not have been telling his tax team, presumably at some point his political team got wind of the Swiss bank account and recognized how damaging it could be to his presidential ambitions. But because Romney has refused to release more information about his finances, answers to questions about his wealth, and particularly about this one account, are black boxed. That’s left him vulnerable to a slow drip of dark-toned speculation from his political enemies. As the experts I’ve spoken to suggest, there could be less nefarious explanations that place Romney on the right side of the law — but still expose to public scrutiny the tax avoidance schemes Romney used and that are only available to the very wealthiest Americans."