Tax

Alma Trade LLC v. USA: Motion to Quash IRS Summonses

Notice of Motion to Quash IRS Summonses issued to JPMorgan Chase Bank, Santander NA, and TD Bank regarding "the Russian Income Tax Liabilities of JSC Topprom" in Alma Trade LLC v. USA at the U. S. District Court for the Southern District of New York.

USA v. Heng Cheong Pacific Ltd. et al: Motion to Withdraw Reference

Motion to Withdraw Bankruptcy Reference regarding "a long-running saga to collect the $20 million-plus tax liabilities of Ronald and Annette Talmage" and "a transparent attempt to collaterally attack three prior federal judgments in favor of the United States" in USA v. Cosimo Borrelli and Colin Wilson, as the Foreign Representatives of Heng Cheong Pacific Limited, World-Wide Investment Services (BVI) Limited, and New Century Properties Limited, all of the British Virgin Islands, at the U. S. District Court for the District of Utah.

USA v. $4.9M Butterfield Bank: Amended Forfeiture Complaint

Forfeiture Complaint in USA v. $4.9 million belonging to The Bank of N.T. Butterfield & Son Limited, of Bermuda, to settle tax evasion allegations involving its Bermuda and Cayman Islands operations, filed at the U. S. District Court for the Southern District of New York.

USA v. $4.9M Butterfield Bank: Forfeiture Complaint

Forfeiture Complaint in USA v. $4.9 million belonging to The Bank of N.T. Butterfield & Son Limited to settle tax evasion allegations, filed at the U. S. District Court for the Southern District of New York.

Butterfield Bank admits ‘criminal conduct’, turns over client records & agrees to pay $5.6M to settle tax evasion investigation

Butterfield Bank has turned over client records and agreed to forfeit $4.9 million that it received in fees and pay restitution of $704,000 under a Non-Prosecution Agreement with the U. S. Department of Justice in which the bank admitted "criminal conduct" by fraudulently helping U.S. taxpayers evade taxes via its Bermuda and Cayman Islands operations.

USA v. Monel Herscovici: Complaint

Complaint "to reduce FBAR penalty to judgment" regarding bank accounts in Liechtenstein and Switzerland in USA v. Monel Herscovici at the U. S. District Court for the Central District of California.

Belgium FPSF v. Lion Advisory Inc. Pension Plan et al: ‘€6.5M Tax Fraud’ Complaint

Complaint for €6.5 million alleging "a fraudulent scheme that caused FPSF Belgium to pay large amounts of money to putative entities in the United States claiming to be owed tax refunds relating to corporate dividends" in Kingdom of Belgium Federal Public Service Finance, described as Belgium's tax collection agency v. Lion Advisory Inc. Pension Plan, described as a New York-based "trust recognized by the U.S. Internal Revenue Service"; Richard Markowitz, of New York; Luke McGee, of Philadelphia, Pennsylvania; John van Merkensteijn, of New York; FGC Securities LLC, described as being domiciled in Delaware and based in New York, and Stephen Wheeler, of Shrewsbury, New Jersey, at the U. S. District Court for the Southern District of New York.

Belgium FPSF v. Xiphias LLC Pension Plan et al: ‘€7.9M Tax Fraud’ Complaint

Complaint for €7.9 million alleging "a fraudulent scheme that caused FPSF Belgium to pay large amounts of money to putative entities in the United States claiming to be owed tax refunds relating to corporate dividends" in Kingdom of Belgium Federal Public Service Finance, which is Belgium's tax collection agency v. Xiphias LLC Pension Plan, described as a New York-based "a trust recognized by the U.S. Internal Revenue Service"; Richard Markowitz, of New York; Matthew Stein, of New York; John van Merkensteijn, of New York; FGC Securities LLC, described as being domiciled in Delaware and based in New York; Alicia Colodner, of New York, and Stephen Wheeler, of New Jersey, at the U. S. District Court for the Southern District of New York.

Belgium FPSF v. Ganesha Industries Pension Plan et al: ‘€6.8M Tax Fraud’ Complaint

Complaint for €6.8 million alleging "a fraudulent scheme that caused FPSF Belgium to pay large amounts of money to putative entities in the United States claiming to be owed tax refunds relating to corporate dividend" in Kingdom of Belgium Federal Public Service Finance, which is Belgium's tax collection agency v. Ganesha Industries Pension Plan, described as a New York-based "trust recognized by the U.S. Internal Revenue Service"; Adam LaRosa, of New Jersey; Jerome L'Hote, of New York; FGC Securities LLC, of New York, and Stephen Wheeler, of New Jersey, at the U. S. District Court for the Southern District of New York.

Belgium FPSF v. Traden Investments Pension Plan et al: ‘€6.3M Tax Fraud’ Complaint

Complaint for €6.3 million alleging "a fraudulent scheme that caused FPSF Belgium to pay large amounts of money to putative entities in the United States claiming to be owed tax refunds relating to corporate dividends" in Kingdom of Belgium Federal Public Service Finance, which is Belgium's tax collection agency v. Traden Investments Pension Plan, described as a New York-based "trust recognized by the U.S. Internal Revenue Service"; Adam LaRosa, of New Jersey; FGC Securities LLC, described as being domiciled in Delaware and based in New York, and Stephen Wheeler, of New Jersey, at the U. S. District Court for the Southern District of New York.

Belgium FPSF v. Michelle Investments LLC Pension Plan et al: ‘€6M Tax Fraud’ Complaint

Complaint for €6 million alleging "a fraudulent scheme that caused FPSF Belgium to pay large amounts of money to putative entities in the United States claiming to be owed tax refunds relating to corporate dividends" in Kingdom of Belgium Federal Public Service Finance v. Michelle Investments LLC Pension Plan, of New York; Richard Markowitz, of New York; John van Merkensteijn, of New York; FGC Securities LLC, of New York; Alicia Colodner, of New York, and Stephen Wheeler, of New Jersey, at the U. S. District Court for the Southern District of New York.

Belgium FPSF v. Delvian LLC Pension Plan et al: ‘€6.3M Tax Fraud’ Complaint

Complaint for €6.3 million alleging "a fraudulent scheme that caused FPSF Belgium to pay large amounts of money to putative entities in the United States claiming to be owed tax refunds relating to corporate dividends" in Kingdom of Belgium Federal Public Service Finance v. Delvian LLC Pension Plan, of New York; Alicia Colodner, of New York; Richard Markowitz, of New York; John van Merkensteijn, of New York; FGC Securities LLC, of New York, and Stephen Wheeler, of New Jersey, at the U. S. District Court for the Southern District of New York.

Belgium FPSF v. AOI Pension Plan et al: ‘€5.9M Tax Fraud’ Complaint

Complaint for €5.9 million alleging "a fraudulent scheme that caused FPSF Belgium to pay large amounts of money to putative entities in the United States claiming to be owed tax refunds relating to corporate dividends" in Kingdom of Belgium Federal Public Service Finance v. AOI Pension Plan, of New York; Adam LaRosa, of New Jersey; Matthew Stein, of New York; FGC Securities LLC, of New York, and Stephen Wheeler, of New Jersey, at the U. S. District Court for the Southern District of New York.

USA v. Federal Express et al: Order

Order granting a petition for Leave to Serve 'John Doe' Summonses as part of an IRS investigation into U.S. taxpayers who are suspected of tax evasion using the services of Panama Offshore Legal Services in USA v. Federal Express Corporation, a.k.a. FedEx Express; Fed Ex Ground Package System, Inc., a.k.a. FedEx Ground; DHL Express (USA), Inc., United Parcel Service, Inc., the Federal Reserve Bank of New York, The Clearing House Payments Company LLC, HSBC Bank USA, N.A., Citibank, N.A., Wells Fargo Bank, N.A., and Bank of America, N.A. at the U. S. District Court for the Southern District of New York.

USA v. Isac Schwarzbaum: Magistrate Judge’s Recommendation

U.S. Magistrate Judge's Report Recommending that the USA's Motion to Repatriate Foreign Assets be granted to satisfy a judgment in excess of $15 million for failure to disclose foreign accounts in Costa Rica and Switzerland in USA v. Isac Schwarzbaum, who was born in Germany and lives in Florida, at the U. S. District Court for the Southern District of Florida.

USA v. Federal Express et al: ‘John Doe’ Summonses Supplemental Information

Supplemental Memorandum of Law and Declaration in support of a petition for Leave to Serve 'John Doe' Summonses as part of an IRS investigation into U.S. taxpayers who are suspected of tax evasion using the services of Panama Offshore Legal Services in USA v. Federal Express Corporation, a.k.a. FedEx Express; Fed Ex Ground Package System, Inc., a.k.a. FedEx Ground; DHL Express (USA), Inc., United Parcel Service, Inc., the Federal Reserve Bank of New York, The Clearing House Payments Company LLC, HSBC Bank USA, N.A., Citibank, N.A., Wells Fargo Bank, N.A., and Bank of America, N.A. at the U. S. District Court for the Southern District of New York.

Jen Zhang et al v. USA: Petition to Quash IRS Summons

Petition to Quash Third-Party Summons Issued to Wells Fargo Bank N.A. by the IRS in Jen (Hwa Yu) Zhang and Charles (Zhi Yu) Zhang, Canadian citizens who are "targets of a criminal investigation in Canada" that alleges "violations of the Customs Act, the Criminal Code, the Excise Tax Act, and the Special Import Measures Act" v. USA at the U. S. District Court for the Northern District of California.

USA v. Swiss Life: Forfeiture Complaint

Forfeiture Complaint regarding $35 million associated with alleged tax evasion activity by "Swiss Life Holding AG, a Swiss insurance holding company, and three of its subsidiaries, Swiss Life (Liechtenstein) AG, Swiss Life (Singapore) Pte. Ltd., and Swiss Life (Luxembourg) S.A." in USA v. $35 Million at the U. S. District Court for the Southern District of New York.

USA v. Isac Schwarzbaum: USA’s Motion to Repatriate Foreign Assets

Motion to Repatriate Foreign Assets to satisfy a judgment "in excess of $15 million" for failure to disclose foreign accounts in Costa Rica and Switzerland in USA v. Isac Schwarzbaum, who was born in Germany and lives in Florida, at the U. S. District Court for the Southern District of Florida.

USA v. John Glaister: Complaint

Complaint under the Bank Secrecy Act to collect penalties totaling $300,000 for allegedly failing to disclose "a financial interest in an account at National Westminster Bank plc, also known as NatWest, in the United Kingdom" in USA v. John Glaister, described as "a professional real estate consultant with foreign clients, including in Germany and Scotland", at the U. S. District Court for the Southern District of New York.

USA v. David Sinyavskiy: Complaint

Complaint "to reduce to judgment and collect outstanding civil penalties" totaling $80,724 for "non-willful failure to timely report his financial interest in foreign bank accounts" involving an account at Rothschild Bank AG, in Zurich, Switzerland, in USA v. David Sinyavskiy, described as a former resident of Ukraine who became a United States citizen, at the U. S. District Court for the Eastern District of New York.

USA v. Swiss Life Holding AG et al: Deferred Prosecution Agreement

Deferred Prosecution Agreement, with exhibits that include a Criminal Information, Statement of Facts, and Forfeiture Complaint, in USA v. Swiss Life Holding AG, of Switzerland; Swiss Life (Liechtenstein) AG, of Liechtenstein; Swiss Life (Luxembourg) SA, of Luxembourg, and Swiss Life (Singapore) Pte. Ltd., of Singapore, who agreed to pay $77 million to settle a criminal charge of what the USA described in an accompanying news release as "conspiring with U.S. taxpayers and others to conceal from the Internal Revenue Service more than $1.452 billion in offshore insurance policies, including more than 1,600 insurance wrapper policies, and related policy investment accounts in banks around the world and the income generated in these accounts", filed at the U. S. District Court for the Southern District of New York.

USA v. Swiss Life Holding AG et al: Criminal Information

Criminal Information alleging conspiracy to defraud the United States in USA v. Swiss Life Holding AG, of Switzerland; Swiss Life (Liechtenstein) AG, of Liechtenstein; Swiss Life (Luxembourg) SA, of Luxembourg, and Swiss Life (Singapore) Pte. Ltd., of Singapore, at the U. S. District Court for the Southern District of New York.

Cairn Energy Plc et al v. Air India Ltd.: Complaint

Complaint "to determine and resolve questions of actual controversy involving the relationship between India's wholly-owned national airline, Air India, and India, and in particular, whether Air India is the alter ego of India" and for "a money judgment adjudging that Air India is jointly and severally liable to satisfy the judgment Plaintiffs expect to be awarded against India based on a pending petition to confirm an arbitration award" for $1.2 billion in Cairn Energy Plc and Cairn UK Holdings Limited, both of Scotland v. Air India Ltd., of India, at the U. S. District Court for the Southern District of New York.

Brazil: Carlos Antonio Lemos da Fonseca et al

Application for the appointment of a Commissioner to collect evidence from Ocean Bank - pursuant to a request for judicial assistance from Brazil - for a criminal investigation into "Carlos Antonio Lemos da Fonseca, Brasita Cigarros Industria e Comercio Ltda., and other individuals for six offenses, specifically, tax fraud, false statement, falsification of public seal or sign, criminal organization, unauthorized exchange operation, and money laundering".

USA v. Federal Express et al: ‘John Doe’ Summonses Petition

Ex Parte Petition for Leave to Serve 'John Doe' Summonses as part of an IRS investigation into U.S. taxpayers who are suspected of tax evasion using the services of Panama Offshore Legal Services, described as "a Panamanian law firm that has been providing offshore services since 2000", allegedly offering legal structures formed in several jurisdictions, including Belize, the British Virgin Islands, Delaware, Nevis, Nevada, Panama, Saint Vincent and the Grenadines, and Switzerland, in USA v. Federal Express Corporation, a.k.a. FedEx Express; Fed Ex Ground Package System, Inc., a.k.a. FedEx Ground; DHL Express (USA), Inc., United Parcel Service, Inc., the Federal Reserve Bank of New York, The Clearing House Payments Company LLC, HSBC Bank USA, N.A., Citibank, N.A., Wells Fargo Bank, N.A., and Bank of America, N.A. at the U. S. District Court for the Southern District of New York.

USA v. Western Union: ‘John Doe’ Summons Petition

Ex Parte Petition for Leave to Serve 'John Doe' Summons as part of an IRS investigation into U.S. taxpayers who are suspected of tax evasion using the services of Panama Offshore Legal Services, described as "a Panamanian firm that assists clients in concealing their beneficial ownership of assets", in USA v. Western Union Financial Services Inc. at the U. S. District Court for the District of Colorado.

USA v. MoneyGram: ‘John Doe’ Summons Petition

Ex Parte Petition for Leave to Serve 'John Doe' Summons as part of an IRS investigation into U.S. taxpayers who are suspected of tax evasion using the services of Panama Offshore Legal Services, described as "a Panamanian firm that assists clients in concealing their beneficial ownership of assets", in USA v. MoneyGram Payment Systems Inc. at the U. S. District Court for the District of Minnesota.

Lithuania: ESmotorsport

Application for the appointment of a Commissioner to collect evidence from IAA, Inc., described as an "online auction business" - pursuant to a request for judicial assistance from Lithuania - for a criminal investigation into ESmotorsport, of Lithuania, for suspected fraud and tax evasion.

Morten Høegh et al v. Taylor Wessing LLP et al: Complaint

Amended Claim Form and Particulars of Claim alleging negligent advice regarding tax liabilities in the United Kingdom of plaintiffs who were associated with "offshore investments" and "offshore structures" in Bermuda, British Virgin Islands, and Guernsey in Morten Høegh and Thomas Høegh, described as Norwegians who were "tax resident in the UK and domiciled in Norway" v. Taylor Wessing LLP, a law firm, and MSR Partners LLP, f.k.a. Moore Stephens LLP, an accounting firm, at the High Court of Justice for England and Wales.

USA v. Carlos Kepke: Criminal Indictment

Criminal Indictment alleging tax fraud conspiracy involving accounts or companies in Belize, British Virgin Islands, Cayman Islands, Nevis, and Switzerland in USA v. Carlos E. Kepke, who was described as "an attorney specializing in creating and maintaining foreign trusts and companies for his clients", at the U. S. District Court for the Northern District of California.

USA v. Rahn+Bodmer Co.: $9.7M Forfeiture Complaint

Forfeiture Complaint regarding a "fraud conspiracy" involving U.S. taxpayers in USA v. Rahn+Bodmer Co., of Switzerland, at the U. S. District Court for the Southern District of New York.

USA v. Kraken: ‘John Doe’ Summons

USA's Ex Parte Petition for Leave to Serve IRS 'John Doe' Summons on Payward Ventures Inc. and subsidiaries, d.b.a. Kraken or Kraken.com, as part of "an investigation to determine the correct federal income tax liabilities for taxable years 2016-2020 of United States taxpayers who have conducted transactions in cryptocurrency", filed at the U. S. District Court for the Northern District of California.

USA v. Circle Internet Financial Inc.: ‘John Doe’ Summons

USA's Ex Parte Petition for Leave to Serve an IRS 'John Doe' Summons on "Circle Internet Financial Inc., or its predecessors, subsidiaries, divisions, affiliates, including Poloniex LLC" as part of an investigation into suspected cryptocurrency-related tax fraud, filed at the U. S. District Court for the District of Massachusetts.

USA v. Colorado Property et al: Forfeiture Complaint

Forfeiture Complaint in USA v. Property in Colorado and $77 million held in the name of Edge Capital Investments Ltd., of Nevis, at Mirabaud Bank, in Switzerland, that are "directly traceable" to a "debt buyback fraud scheme" involving, inter alia, Robert Brockman, Robert Smith, Evatt Tamine, and companies and accounts in Bermuda, British Virgin Islands, Nevis, and Switzerland at the U. S. District Court for the District of Colorado.

USA v. Rahn+Bodmer Co.: Deferred Prosecution Agreement

Deferred Prosecution Agreement regarding an alleged conspiracy to help U.S. taxpayers commit tax evasion in USA v. Rahn+Bodmer Co., a Swiss private bank, at the U. S. District Court for the Southern District of New York.

USA v. Rahn+Bodmer Co.: Criminal Information

Criminal Information alleging conspiracy to help U.S. taxpayers commit tax evasion in USA v. Rahn+Bodmer Co., a Swiss private bank, at the U. S. District Court for the Southern District of New York.

Ambitions Ltd.: Revocation

Public Statement by the Isle of Man Financial Services Authority that it has revoked the registration of Ambitions Limited after its director Richard Ian Kissack "pleaded guilty to eight counts of VAT fraud and one count of VAT evasion".

Finchpay Ltd.: Revocation

Public Statement by the Isle of Man Financial Services Authority that it has revoked the registration of Finchpay Limited after its director Richard Ian Kissack "pleaded guilty to eight counts of VAT fraud and one count of VAT evasion".

SKAT v. Paul Oakley et al: Amended Defense

Amended Defense involving allegations of tax fraud in Skatteforvaltningnen, a.k.a. SKAT, (the Danish Customs and Tax Administration) v. Paul Oakley, Owen Mitchell, and Orca Investments Limited at the High Court of Justice, in London, England.

SKAT v. Alba Gonzalez Brown: Amended Defense

Amended Defense in Skatteforvaltningnen, a.k.a. SKAT, (the Danish Customs and Tax Administration) v. Alba Gonzalez Brown at the High Court of Justice, in London, England.

Slovenia: Matjaz Ferk

Complaint for the extradition of Matjaz Ferk, a.k.a. Matt Ferk, from the USA to Slovenia to face allegations of fraud and tax evasion, filed at the U. S. District Court for the Eastern District of Tennessee.

USA v. ‘Tax Refund Fraud Proceeds’: Forfeiture Complaint

Forfeiture Complaint regarding funds that are suspected of being the proceeds of an alleged $4.7 million tax refund fraud and money laundering scheme that utilized "Green Dot" prepaid debit cards, Fiserv "bill pay service", and Mailbox Forwarding in USA v. Funds Formerly on Deposit at Bank of America at the U. S. District Court for the Southern District of Florida.

Mossack Fonseca & Co. et al v. Netflix Inc.: Order Striking Complaint

Order Granting Defendant's Special Motion to Strike Plaintiff's Second Amended Complaint alleging defamation and trademark infringement regarding the movie 'The Laundromat' about the 'Panama Papers' investigation by the International Consortium of Investigative Journalists in Mossack Fonseca & Co. SA, Bufete MF & Co., Jürgen Mossack, and Ramón Fonseca, all of Panama v. Netflix Inc. at the U. S. District Court for the District of Connecticut.

SKAT v. Bell Rock Group Financial Services Ltd. et al: Judicial Assistance Order

Order granting a request for international judicial assistance to obtain evidence in the Cayman Islands from Bell Rock Group Financial Services Limited, Campbell Corporate Services Limited, CO Services Cayman Limited, DMS Corporate Services Ltd., Forbes Hare Trust Company Limited, Genesis Trust & Corporate Services Ltd., Harneys Services (Cayman) Limited, now known as Harneys Fiduciary (Cayman) Limited; Intertrust Corporate Services (C.I.) Limited, now known as Intertrust Corporate Services (Cayman) Limited; Ocorian (Cayman) Limited, Sterling Trust (Cayman) Limited, Trident Trust Company (Cayman) Limited, Vistra (Cayman) Limited, and Walkers Corporate Limited for legal proceedings in Canada, Dubai, England, Malaysia, and the USA brought by Skatteforvaltningen, a.k.a. SKAT, which is Denmark's tax collection agency, issued at the Grand Court of the Cayman Islands.