Tax

Samuel Malamud Eidelman v. Citibank NA et al: Discovery Application

Ex Parte Application by Samuel Malamud Eidelman to take discovery from Citibank, N.A., Bank Leumi USA, New York Branch; HSBC Bank USA, N.A., BNP Paribas USA, Credit Lyonnais, New York Branch; JPMorgan Chase Bank, N.A., Scotia Bank, New York Agency; IDB Bank, New York Branch; Coutts Bank Switzerland Ltd., New York Branch; Standard Chartered Bank USA, Santander Bank, N.A., and Scotia Capital, Inc. for use in "contemplated" legal proceedings in Peru "against his brother, Jacobo Malamud, and Jacobo’s daughters, Yoselyn Malamud, Yudith Malamud and Caroline Malamud due to the commitment of crimes such as money laundering and tax evasion", filed at the U.S. District Court for the Southern District of New York.

USA v. Raymond Galliani: Complaint

Complaint "to collect unpaid federal civil penalty assessments and interest" from a "sophisticated taxpayer" who "established a maze of offshore entities to conceal his beneficial ownership of entities and foreign financial accounts holding millions of dollars", including those in the Bahamas, Guernsey, and Nevis, in USA v. Raymond Galliani, of Moraga, California, at the U.S. District Court for the Northern District of California.
Kevin Wessell

IRS accuses ‘asset protection expert’ Kevin Wessell of withholding records about suspected offshore tax evasion

Florida-based, self-described "asset protection expert" Kevin Wessell has been accused of withholding records from the IRS that it requires for an investigation into his clients for suspected offshore tax evasion involving accounts and entities in several jurisdictions, including the Bahamas, Belize, British Virgin Islands, Cayman Islands, Cook Islands, Hong Kong, Nevada, Nevis, Panama, Saint Vincent and the Grenadines, Seychelles, Switzerland, and Turks and Caicos Islands.
Evatt Tamine Judgment

Australian lawyer Evatt Tamine ordered to repay $28M to Robert Brockman’s Bermuda trust

In a judgment at Bermuda Supreme Court, Australian barrister Evatt Tamine has been ordered to repay nearly $30 million that he allegedly misappropriated from a Bermuda trust he administered on behalf of U.S. businessman Robert Brockman, who was criminally indicted at federal court in California in 2020 for an alleged $2 billion offshore tax fraud scheme.

USA v. Edward Carriero et al: Petition to Enforce IRS Summonses (‘Investigation into Nevis-Licensed Captive Insurance Arrangements’)

Petition to Enforce IRS Summonses regarding the tax liability of ABS Healthcare Services LLC and Health Option One LLC, both of Deerfield Beach, Florida, collectively doing business as Insurance Care Direct and described as the operators of Nevis-domiciled captive insurers ICD Captive Re Ltd. and HOO Captive Re Ltd., in USA v. Edward Carriero, Seth Cohen, and Bradley Cohen at the U.S. District Court for the Southern District of Florida.

BCT Ltd. et al v. Evatt Tamine et al: $28M Judgment (Robert Brockman Case)

Judgment awarding $16.8 million, $5.395 million, and £5 million against the defendants in BCT Limited, a Cayman Islands subsidiary of Maples Group, as Trustee of the A. Eugene Brockman Charitable Trust, and Spanish Steps Holdings Limited, of the British Virgin Islands v. Evatt Tamine, an Australian barrister, and Tangarra Consultants Limited, of Bermuda, at Bermuda Supreme Court.

Robert Brockman v. IRS: Complaint (‘Records Disclosure’)

Complaint "to compel the disclosure of all government documents and records requested pursuant to FOIA that were unlawfully withheld by Defendant, the Internal Revenue Service" in Robert T. Brockman, a resident of Houston, Texas who was criminally indicted in 2020 for allegedly concealing approximately $2 billion from the IRS and swindling investors in his firm using offshore structures in Bermuda, British Virgin Islands, Cayman Islands, Nevis, and Switzerland v. Internal Revenue Service at the U. S. District Court for the District of Columbia.

USA v. Paul Manafort: Complaint (‘Failure to Report Foreign Bank Accounts’)

Complaint alleging failure to report "consulting income from Ukrainian sources" that was "deposited into accounts ... opened in the countries of Cyprus, St. Vincent and the Grenadines, and the United Kingdom" in USA v. Paul J. Manafort, Jr. at the U. S. District Court for the Southern District of Florida.

Point Investments Ltd.: Chapter 15 Petition

Chapter 15 Petition for Recognition of a Foreign Main Proceeding in Bermuda by Andrew Childe, Richard Lewis, and Matthew Clingerman, as the Foreign Representatives of Point Investments Ltd., a Bermuda company whose ultimate beneficiaries include Robert Brockman, a businessman in the United States who is currently awaiting trial for an alleged $2 billion tax fraud scheme involving Point Investments and other entities in Bermuda, British Virgin Islands, Cayman Islands, Nevis, and Switzerland, filed at the U. S. Bankruptcy Court for the District of Delaware.

USA v. Ronald Thomas: Criminal Information

Criminal Information alleging tax fraud in USA v. Ronald L. Thomas, described as "a United States citizen who lived in Wellington, Florida, and intermittently Dubai, United Arab Emirates" and was "an independent contractor for a United States Department of Defense contractor as a Country Manager in Kabul, Afghanistan", "a Project Director in Oman for the Middle East", and a "paid consultant to a Mexican oil and gas joint venture", at the U. S. District Court for the District of Columbia.

Reliance Globalcom Ltd. v. Bermuda Minister of Finance: Appeal Judgment (‘Indian Tax Investigation’)

Judgment allowing an appeal that challenged a production order obtained under the International Cooperation (Tax Information Exchange Agreements) Act 2005 to disclose information for a tax investigation by the "Indian Tax Authorities" in Reliance Globalcom Limited, whose ultimate beneficial owners were identified as Mukesh Ambani and Anil Ambani v. The Minister of Finance at Bermuda Court of Appeal.

USA v. Robert Brockman: Transcript of Competency Hearing

Transcript of Competency Hearing in USA v. Robert T. Brockman, who has been criminally charged with conspiracy to defraud the USA, tax evasion, wire fraud, FBAR violations, money laundering, evidence tampering, and destruction of evidence regarding an alleged scheme to conceal approximately $2 billion of capital gains income and involving entities and accounts in Bermuda, British Virgin Islands, Cayman Islands, Nevis, and Switzerland, at the U.S. District Court for the Southern District of Texas.

USA v. Mubarek Said: Complaint

Complaint "to collect outstanding civil penalties assessed against Defendant Mubarek Said for his failure to timely report his financial interest in foreign bank accounts", including those at National Commercial Bank and First Global Bank, both in Jamaica, in USA v. Mubarek Said at the U. S. District Court for the Southern District of Florida.

Evatt Tamine v. Bermuda Press (Holdings) Ltd.: Redacted Ruling

Redacted Ruling denying the defendant's application for an order to discharge an ex parte order regarding "articles and hyperlinks to documents in the articles as published on the RG Online" involving Robert Brockman, described as "a US national who is presently under indictment in the United States for charges of tax fraud", in Evatt Anthony Tamine, an Australian lawyer v. Bermuda Press (Holdings) Ltd., publisher of The Royal Gazette daily newspaper in Bermuda, at Bermuda Supreme Court.

Compass Star Ltd. v. International Tax Authority: Judgment (‘UK HMRC Investigation’)

Judgment dismissing a claim by the Claimant "to have the Court review the decision of the International Tax Authority to serve a notice on it requiring production of specific information" pursuant to a request from the United Kingdom's Revenue & Custom's Department in Compass Star Limited, which provides "an IT platform for those requiring documented vetting processes for directors or other corporate officers in respect of the requirements of the Companies Act 2006 of England and Wales" v. International Tax Authority at the British Virgin Islands High Court.

SPS Corp I v. General Motors et al: Discovery Application

Application by SPS Corp I - Fundo de Investimento em Direitos Creditórios Não Padronizados, described as "a Brazilian entity that purchased the IPI tax indemnification rights of 35 car dealerships in Brazil", to take discovery from General Motors Co., Deloitte & Touche LLP, and Ernst & Young LLP for use in "pending and contemplated Brazilian legal proceedings against GM’s wholly owned subsidiary, General Motors do Brasil LTDA., for monies that GM Brazil owes the Applicant in connection with a three-decade-long tax dispute between GM Brazil and the Brazilian federal government for tax credits paid by several GM car dealerships in Brazil", filed at the U. S. District Court for the District of Delaware.

Vistra (BVI) sued over audits of DC Solar’s “multi-billion-dollar fraud”

British Virgin Islands-based corporate services provider Vistra and accountant Indervir Basra, who works for the group in California, are being sued in the United States regarding audits of DC Solar, which collapsed after swindling investors out of an estimated $1 billion. The audits were allegedly conducted by a group that Vistra acquired just seven months before DC Solar's headquarters was raided by the FBI in December, 2018.

East West Bank et al v. Vistra (BVI) et al: Complaint

Complaint alleging aiding and abetting fraud, concealment, and negligence regarding the auditing of "a multi-billion-dollar fraud" by DC Solar Funds and DC Solar Solutions in East West Bank, East West Bancorp Inc., Progressive Casualty Insurance Company, GEICO Corporation, The Sherwin-Williams Company, People's United Bank NA, People's United Financial Inc., Adhi-Solar LLC, DV VNB Community Renewables Fund LLC, DV VNB Community Renewables Fund III LLC, and Pardee Solar 1 LLC v. Vistra Group Holdings (BVI) Limited, of the British Virgin Islands; Vistra Group Holdings (BVI) I Limited, of the British Virgin Islands, and Indervir Basra, of California, at the Superior Court of the State of California, County of Los Angeles.

Tax Enforcement Update: The IRS v. Offshore

In this video, IRS senior representatives discuss the Agency's offshore tax enforcement initiatives, past, present, and future. Speakers: Damon Rowe (Internal Revenue Service), Jason Bell (Internal Revenue Service), Mark Daly (Department of Justice)

RGN Malta Ltd.: €60K Fine

Public Notice by the Malta Financial Intelligence Analysis Unit that it has imposed a fine of €60,000 on RGN Malta Limited for regulatory breaches involving a corporate customer's beneficial ownership and suspected involvement in tax evasion.

USA v. James C. Jones Jr.: Criminal Indictment

Criminal Indictment alleging tax evasion involving, inter alia, entities in Anguilla and Sint Maarten in USA v. James C. Jones, Jr. at the U. S. District Court for the Southern District of Florida. Editor's Note: The indictment was filed under seal at the U. S. District Court for the Western District of Virginia on August 20th, 2020 and removed to federal court in Fort Lauderdale and unsealed on October 29th, 2021.

USA v. Vladimir Mrvic: Complaint

Complaint "to collect his unpaid federal penalty assessments and interest related to his financial interests in foreign bank accounts" in USA v. Vladimir Mrvic, described as "a dual citizen of the United States and Serbia", at the U. S. District Court for the Southern District of New York.

Samuel Galib v. USA: Complaint

Complaint for refund and abatement of FBAR penalty in Samuel H. Galib, who, together with his brother, "inherited their mother's account with HSBC bank in Switzerland" and later participated in the IRS' Offshore Voluntary Disclosure Program v. USA at the U. S. District Court for the Eastern District of Pennsylvania.

Apex Financial Services (Trustees) Ltd. v. Wiggin Osborne Fullerlove: Complaint

Complaint for damages of £353,002 alleging professional negligence involving 'Inheritance Tax' liabilities of a trust settled by Lance Uggla, described as a "UK resident but foreign domiciled for income and capital gains tax purposes", in Apex Financial Services (Trustees) Ltd., of Jersey, in the Channel Islands v. Wiggin Osborne Fullerlove, a law firm based in Cheltenham, Gloucestershire, England, at the High Court of Justice for England and Wales.

Samuel Tcherassi v. Yolanda Janna: Discovery Application

Application by Samuel Tcherassi to take discovery from Yolanda Janna, of Miami, "for use in a foreign criminal investigation" in Colombia that "stems from a complaint filed by Henry Anaya, the president of a Colombian non-governmental organization, National Network of Citizen Observers" who requested that "the Colombian Prosecutor's Office investigate Tcherassi and Diana Janna (Tcherassi's wife)" for alleged tax offenses, filed at the U. S. District Court for the Southern District of Florida.
Pandora Papers

Webinar: The ICIJ’s ‘Pandora Papers’ Investigation

The ICIJ will discuss its ‘Pandora Papers’ investigation into financial secrecy during a free OffshoreAlert webinar this Friday. Based on “11.9 million leaked records”, the ICIJ describes the investigation as “the largest in journalism history” and says it “exposes a shadow financial system that benefits the world’s most rich and powerful”.

Gerobin Finances Pty Ltd. et al: Chapter 15 Petition

Chapter 15 Petition for Recognition of a Foreign Main Proceeding in Australia by Sheahan and Lock, as the Foreign Representatives of Gerobin Finances Pty Ltd., Erbin Finances Pty Limited, Rawbin Finances Pty Limited, Marbin Finances Pty Limited, Erma Nominees Pty Limited, and Ligon 158 Pty Limited, described as members of "a remarkably complex group of companies controlled and operated by, and used for the personal benefit of, the Binetter family, many of which companies have been the subject of a far-ranging tax investigation by the Australian Taxation Office", filed at the U. S. Bankruptcy Court for the Southern District of New York.

USA v. Mark Gyetvay: Release & Conditions Order

Order of Release on $80 million bond and other conditions in USA. Mark Gyetvay, the Chief Financial Officer of Russian gas producer Novatek who is apparently a citizen of Italy, Russia, and the United States, at the U. S. District Court for the Middle District of Florida.

USA v. Mark Gyetvay: USA’s Motion for Conditions of Release

Motion to Set Conditions of Release in USA v. Mark Gyetvay, a citizen of Italy, Russia, and the United States charged with "a decade-long tax evasion scheme that involved his failure to report over $40 million of income to the IRS", at the U. S. District Court for the Middle District of Florida.

USA v. Mark Gyetvay: Criminal Indictment

Criminal Indictment alleging tax evasion involving companies or accounts in Belize, British Virgin Islands, Cayman Islands, Russia, and Switzerland in USA v. Mark Gyetvay, the Chief Financial Officer of Russian gas producer Novatek who is apparently a citizen of Italy, Russia, and the United States, at the U. S. District Court for the Middle District of Florida.

USA v. Evo Bechtiger et al: Criminal Indictment

Criminal Indictment alleging "a fraudulent scheme referred to by the conspirators as the 'Singapore Solution'" involving entities in the British Virgin Islands, Hong Kong, Liechtenstein, Singapore, and Switzerland in USA v. Evo Bechtiger, Bernhard Lampert, Peter Rüegg, Roderic Sage, Rolf Schnellmann, Daniel Wächli, and Allied Finance Trust AG, described as "a financial services company in Zurich", at the U. S. District Court for the Southern District of New York.

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. Robert Brockman: USA’s Opposition to Tangarra’s Motion to Strike

USA's Opposition to Motion to Strike by Bermuda-domiciled Tangarra Consultants Ltd. in USA v. Robert T. Brockman at the U. S. District Court for the Southern District of Texas.Editor's Note: This document, which is publicly-available from federal court in the United States, is the subject of ongoing legal proceedings at Bermuda Supreme Court in which Tangarra's principal, Evatt Tamine, an Australian lawyer who provided services to Brockman (a software tycoon who was criminally indicted in the US for an alleged $2 billion tax fraud), obtained an injunction that legally prohibits Bermuda Press (Holdings) Ltd., the publisher of local daily newspaper The Royal Gazette, from publishing an exhibit to the document, specifically a 56-page affidavit by Tamine, who is a self-described "cooperating witness" in the US criminal action against Brockman. Bermuda Judge Larry Mussenden ruled that “the confidentiality” of Tamine’s affidavit had not been lost by its “limited publication” on the US Court’s website. To eliminate that as a credible argument, OffshoreAlert has today not only published the contentious document but made it available to everyone for free (both subscribers and non-subscribers). We do so in the public interest. Bermuda Supreme Court has a long history of draconian secrecy, first by denying the general public access to any writs for over 40 years and then, after Bermuda’s Chief Justice acknowledged in 2015 that the practice was essentially illegal, continuing to seal entire business-related cases and writs on a disturbingly-high scale, an inevitable consequence of which is that questionable conduct by Bermuda entities is concealed from existing clients, potential clients, and everyone else.

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.

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. 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.

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. 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. 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.