November 28, 2011
We will be attending the 28th Annual National Institute on Criminal Tax Fraud and the First National Institute on Tax Controversy conference on December 1-2, 2011 in Las Vegas.
The conference brings together members of the criminal tax defense bar, Department of Justice and IRS representatives, judges, and corporate counsel. Discussion topics range from hot areas of criminal tax enforcement from the Department of Justice to international tax enforcement actions, including voluntary disclosure and FATCA.
View full program.
Hope to see you there!
Sean McMahon and Bill Lovett
November 21, 2011
Renzo Gadola, a former senior banker at UBS AG, was recently sentenced to five years probation for his role in advising U.S. citizens on how to conceal funds in offshore accounts.
Gadola was arrested in November 2010 in Miami after he was caught on tape advising a client not to disclose a previously undeclared Swiss bank account. Gadola pled guilty in December 2010 to conspiring to impede and impair the IRS and became a key cooperator in the U.S. government’s widening investigation of Americans and Swiss banks suspected of hiding assets to evade billions in taxes. Read Gadola Criminal Complaint and Statement of Facts.
Gadola provided detailed information on clients and colleagues, as well as the role of Swiss cantonal banks in holding offshore accounts has led to charges being brought against two former colleagues, Martin Lack and Christos Bagios, and at least one former client.
Bagiosis is accused of helping more than 100 U.S. citizens hide more than $500 million from the IRS and is awaiting trial. Lack, a fugitive, was also charged with helping clients evade taxes through the use of offshore bank accounts.
The Gadola case is just one of several recent high profile cases involving offshore Swiss accounts. And a preview of many more to come, as evidenced by indictment of seven current and former Credit Suisse bankers in July 2011. Read Adami Superseding Indictment.
See Also Credit Suisse Discloses Account Records of 130 US Citizens to IRS
November 15, 2011
For the second time in the past two years, a Swiss bank has handed over client records to the IRS. Rupert Neate reports in the Guardian that Credit Suisse, the second largest bank in Switzerland, has produced details on 130 Americans suspected of evading billions of dollars in taxes.
This latest crack down on unreported offshore accounts comes less than three months after the 2011 Offshore Voluntary Disclosure Initiative (“OVDI”) deadline of August 31, 2011. Criminal investigations are also being conducted on 11 financial institutions, including Credit Suisse, for facilitating tax evasion by U.S. citizens.
With prosecuting secret offshore bank accounts being one of the U.S. Department of Justices top priorities, we are likely to see more investigations and criminal charges in the coming months.
See the U.S. Department of Justice’s Offshore Compliance Initiative website.
See Rupert Neate’s report in the Guardian.