Tax

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.

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.

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.

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.

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.: 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.

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.

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".

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".

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.

Lithuania: Darius Vitkus

Complaint to extradite Darius Vitkus, described as "the sole owner and shareholder Gvidonas UAB", from the USA to Lithuania to face charges of fraud, forgery, misappropriation, tax evasion, and theft.

Regina v. Dominic Chappell: Sentencing Remarks

Sentencing Remarks regarding tax fraud involving "the acquisition, and subsequent management, of the British Home Stores chain of department stores" in Regina v. Dominic Chappell at Southwark Crown Court, in England.

USA v. Edge Capital Investments Ltd.: Forfeiture Application

Application for a warrant to seize $77.8 million held at Mirabaud Bank, in Switzerland, that originated from Bermuda Commercial Bank and is the suspected proceeds of an alleged fraud and money laundering scheme involving "two U.S. billionaires, Robert Smith and Robert Brockman" in USA v. Edge Capital Investments Ltd., of Nevis, at the U. S. District Court for the District of Colorado.

US tycoon Robert Brockman indicted for ‘$2B offshore tax fraud scheme’

US software tycoon Robert Brockman has been criminally indicted in California for an alleged $2 billion offshore tax evasion scheme involving accounts and entities in Bermuda, British Virgin Islands, Cayman Islands, Nevis, and Switzerland. In a related case, billionaire private equity boss Robert Smith agreed to pay penalties of $139 million to avoid prosecution.

USA v. Robert F. Smith: Deferred Prosecution Agreement

Deferred Prosecution Agreement in which the defendant agreed to pay tax, penalties, and interest totaling $139.2 million regarding "an illegal scheme to conceal income and evade taxes he owed by using an offshore trust structure with related foreign corporations and offshore bank accounts, and by willfully filing a series of false documents with the Internal Revenue Service" involving entities and accounts in Belize, Bermuda, British Virgin Islands, Cayman Islands, Nevis, and Switzerland in USA v. Robert F. Smith, of Austin, Texas, at the U. S. District Court for the Northern District of California.

Strachans SA: Guilty Plea

News Release by the U.S. Department of Justice entitled 'Jersey/Swiss Financial Services Firm Admits to Conspiring with U.S. Taxpayers to Hide Assets and Income in Offshore Accounts - Strachans SA in Liquidation Pleads Guilty'.

Trinidad and Tobago: Radesh Ramnath

Application for the appointment of a Commissioner to collect evidence from Amerijet International LLC and U.S. Customs and Border Protection - pursuant to a request for judicial assistance from Trinidad and Tobago - for a criminal investigation into Radesh Ramnath, who was "a Trinidad and Tobago Customs and Excise Officer", and unidentified co-conspirators for suspected money laundering, smuggling, and tax evasion.

USA v. Strachans SA: Criminal Judgment

Criminal Judgment imposing a fine of $500,000 for conspiracy to defraud the United States in USA v. Strachans SA (in Liquidation), of Jersey, in the Channel Islands, and Switzerland, at the U. S. District Court for the Central District of California.

USA v. Robert Brockman: Criminal Indictment

Criminal Indictment alleging 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, in USA v. Robert T. Brockman, of Houston, Texas, at the U. S. District Court for the Northern District of California.

USA v. Strachans SA: Criminal Information

Criminal Information alleging conspiracy to defraud the United States in USA v. Strachans SA (in Liquidation), described as "a Jersey-based accounting and financial services company that assisted U.S. taxpayer-clients and others in evading taxes through the use of offshore trusts and entities and offshore bank accounts" that later moved to Switzerland, at the U. S. District Court for the Central District of California. Editor's Note: In the Criminal Information, the USA stated that Strachans moved from Jersey to Switzerland in 1999 and, in 2009, "began doing business as Elston Management". Research by OffshoreAlert in the Swiss Commercial Registry showed that directors, past and present, of Elston Management SA have included Richard Jepson Egglishaw, a citizen of the United Kingdom residing in Monaco; Dino Ferro, a citizen of Italy; Rachel Laure Dupanloup, Henri Bressoud, and Dominique de Weck, of Switzerland.

USA v. Strachans SA: Plea Agreement

Plea Agreement in USA v. Strachans SA (in Liquidation), described as "a Jersey-based accounting and financial services company that assisted U.S. taxpayer-clients and others in evading taxes through the use of offshore trusts and entities and offshore bank accounts" that later moved to Switzerland and "began doing business as Elston Management", at the U. S. District Court for the Central District of California.

Sabena Puri v. USA: Petition to Quash IRS Summons (August 2020)

Petition to Quash Third Party Summons Issued to Citibank NA by the IRS regarding "India Income Tax Liabilities" and an allegation of "political harassment against the current Indian administration's political opposition" in Sabena Puri v. USA at the U. S. District Court for the Central District of California.

Poland: Prima Spolka, LLC et al

Application for the appointment of a Commissioner to collect evidence from CenturyLink - pursuant to a request for judicial assistance from Poland - for a criminal investigation into Prima Spolka, LLC and others for suspected fraud involving value added tax reimbursements.

Hungary: Zsolt Kurányi

Application for the appointment of a Commissioner to collect evidence from JPMorgan Chase Bank regarding Kratos LLC - pursuant to a request for judicial assistance from Hungary - for a criminal investigation into Zsolt Kurányi for tax fraud and money laundering.