A compromise between the U.S. Justice Department and Swiss banking behemoth UBS in their dispute over the release of 52,000 names of U.S. account holders most likely would focus on the more egregious violators who used corporations and foundations to cheat the Internal Revenue Service, tax experts said Monday.

Reports of settlement talks on the IRS demand for names surfaced weeks ago and were confirmed Sunday when both sides asked U.S. District Judge Alan Gold to delay an evidentiary hearing that was set to begin Monday.