The U.S. and Swiss governments are nearing agreement on a comprehensive plan allowing Swiss banks to settle with U.S. authorities over accounts held by U.S. tax evaders. A deal is expected within days, according to officials from both countries.

The plan would create four tiers of banks and require some to pay fines and name names, according to a senior Department of Justice official. The U.S. could collect up to $1 billion or more in penalties from this program, the official said.

...