Posts Tagged With Tax

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Acting Principal Deputy Assistant Attorney General Trevor N. McFadden Speaks at Anti-Corruption, Export Controls & Sanctions 10th Compliance Summit

On April 18, 2017, Acting Principal Deputy Assistant Attorney General Trevor N. McFadden addressed attendees at the Anti-Corruption, Export Controls & Sanctions Compliance Summit in Washington, D.C. about Corporate Social Responsibility.  Referencing his time working in private practice, McFadden expressed his view that “the vast majority of international business and business leaders want to get compliance right.”  He also said that the improvements in corporate compliance were “quite impressive” as compared to before the enactment ... Continue Reading

California Businessman Sentenced to Prison for Concealing over $23.5 Million in Israeli Bank Accounts

On March 13, 2017, Masud Sarshar, the owner and operator of Apparel Limited, Inc. and a resident of Los Angeles, California, was sentenced to 24 months in prison for maintaining undeclared bank accounts at Israeli banks.  Sarshar was also sentenced to three years of supervised release and ordered to pay more than $8.3 million in restitution to the IRS, plus interest and penalties.  Sarshar pled guilty to the charges in August 2016. DOJ Press Release ... Continue Reading

Acting Assistant Attorney General Kenneth A. Blanco Speaks at the American Bar Association National Institute on White Collar Crime

On March 10, 2017, Acting Assistant Attorney General Kenneth A. Blanco addressed the 31st annual American Bar Association White Collar Crime conference about the Criminal Division, and in particular its efforts with respect to white collar crime and corruption in the international arena.  Blanco noted the Department’s success in its anti-money laundering and counter-terrorist financing efforts, as well as its continued efforts in preventing the abuse of shell companies.  Blanco then described the customer due ... Continue Reading

Former Business Professor Sentenced to Prison for Hiding over $220 Million in Offshore Banks

On February 10, 2017, Dan Horsky, a citizen of the United States, United Kingdom and Israel and a former professor of business administration, was sentenced to seven months in prison for conspiring to defraud the United States and to submit a false expatriation statement to the IRS.  According to the plea agreement, Horsky invested in start-up businesses through accounts at offshore banks.  Horsky filed false income tax returns that failed to disclose his beneficial ownership ... Continue Reading

Deutsche Bank Agrees to Pay $95 Million to Resolve Civil Lawsuit Brought by United States in connection with Federal Income Tax Avoidance Allegations

On January 4, 2017, Deutsche Bank, A.G., DB U.S. Financial Markets Holding Corp., and Deutsche Bank Securities, Inc. (collectively, “Deutsche Bank”) agreed to pay $95 million to resolve a civil lawsuit brought by the United States in connection with federal income tax avoidance allegations.  According to the Complaint, Deutsche Bank acquired a corporation in 2000 that held stock with a very low cost basis.  When this stock was sold, Deutsche Bank would incur significant taxable ... Continue Reading

Man Pays $100 Million Penalty in Connection with Tax Fraud Charges Involving $200 Million in Offshore Accounts

On November 4, 2016, Dan Horsky, a citizen of the United States, United Kingdom and Israel and a former professor of business administration, pled guilty to tax fraud charges.  In connection with the plea agreement, Horsky paid a $100 million civil penalty to the U.S. Treasury.  According to the plea agreement, Horsky invested in start-up businesses through financial accounts at offshore banks, including a bank in Switzerland.  By 2008, Horsky’s accounts contained almost $200 million.  ... Continue Reading

Principal Deputy Assistant Attorney General Caroline D. Ciraolo Delivers Remarks at American Bar Association Philadelphia Tax Conference

On November 2, 2016, Principal Deputy Assistant Attorney General Caroline D. Ciraolo delivered remarks at the American Bar Association Philadelphia Tax Conference.  After providing statistics on the DOJ Tax Division’s civil and criminal cases over the last two years, Ciraolo turned to the Tax Division’s current areas of focus.  Ciraolo noted that civil and criminal employment tax enforcement is among the Tax Division’s top priorities.  Ciraolo stated that the Tax Division has filed injunction complaints ... Continue Reading

Owner of Real Estate Investment Firm Sentenced in Manhattan Federal Court to 10 Years in Prison for $17 Million Securities Fraud

On October 28, 2016, Carlton Cabot, the former owner and chief executive officer of Cabot Investment Properties LLC (“CIP”) was sentenced in the Southern District of New York to 10 years in prison and ordered to pay $17 million in restitution and forfeiture for defrauding investors through CIP real estate investments.  Between 2003 and 2012, CIP offered 18 separate tenants-in-common (“TIC”) securities offerings to investors in the United States.  Investors in each security were entitled ... Continue Reading

Tax Attorney and CPA Indicted for Tax Evasion and Diversion of Tax Shelter Fees from Major Manhattan Law Firm

On October 26, 2016, Harold Levine, a Manhattan tax attorney and former head of the tax department at a major Manhattan law firm (“Law Firm”), and Ronald Katz, a Florida certified public accountant, were indicted for allegedly engaging in a multi-year tax evasion scheme to divert millions of dollars in fees from the Law Firm and to conceal that income from the IRS.  According to the indictment, Levine diverted over $3 million in fee income ... Continue Reading

Principal Deputy Assistant Attorney General Caroline D. Ciraolo Delivers Remarks Regarding DOJ’s Efforts to Combat Tax Evasion and Individual Accountability

On September 5, 2016, Principal Deputy Assistant Attorney General Caroline D. Ciraolo delivered remarks at the Cambridge International Symposium on Economic Crime regarding DOJ’s efforts to combat tax evasion.  After providing statistics on the DOJ Tax Division’s efforts to prosecute those who evade taxes, Ciraolo turned to the Tax Division’s focus on individual accountability.  Noting that over one year had passed since Deputy Attorney General Yates spoke of the importance of individual accountability in corporate ... Continue Reading

Jacob “Kobi” Alexander Pleads Guilty to Securities Fraud

On August 24, Jacob “Kobi” Alexander, an Israeli national, pled guilty to one count of securities fraud for his role in an options backdating scheme involving Comverse Technologies Inc.  Alexander was ordered extradited from Namibia on August 22, 2016.  At the time of the offense, Alexander was the Chief Executive Officer and member of the Board of Directors of Comverse, an S&P 500 company.  Between 1998 and 2006, Alexander and his coconspirators engaged in a ... Continue Reading

Principal Deputy Assistant Attorney General Caroline D. Ciraolo Delivers Remarks Regarding Offshore Tax Enforcement Efforts

On August 17, Principal Deputy Assistant Attorney General Caroline D. Ciraolo delivered remarks at the Panama Bankers Association Anti-Money Laundering Conference on the Tax Division’s offshore tax enforcement efforts.  Ciraolo stated that offshore tax enforcement is one of the Tax Division’s highest priorities.  She explained that the one role of the Tax Division is to petition the federal courts to enforce IRS requests for records related to taxpayers’ offshore assets and activities, sometimes through “John ... Continue Reading

Owner of Apparel Limited, Inc. Charged with Conspiring with Israeli Bank to Hide Income and Agreed to Plead Guilty

On August 1, Masud Sarshar, the owner and operator of Apparel Limited, Inc. and a resident of Los Angeles, California, agreed to plead guilty to maintaining undeclared bank accounts at Israeli Banks.  The plea agreement includes a 24-month prison sentence and a restitution amount of $8.3 million to be paid to the IRS.  Sarshar hid tens of millions of dollars in assets in his undisclosed accounts, allowing him to earn interest and avoid individual and ... Continue Reading

After UBS Produces Singapore-Based Documents, Justice Department Dismisses Summons Case

On June 22, DOJ voluntarily dismissed its summons enforcement action against UBS after the bank produced all Singapore-based records responsive to an IRS summons.  The IRS administrative summons was served on UBS for all records pertaining to accounts held by Ching-Ye “Henry” Hsiaw in relation to an investigation into offshore tax evasion.  Announcing the dismissal, Acting Assistant Attorney General Caroline D. Ciraolo of the Tax Division explained that to detect offshore tax evasion, “[o]ne critical ... Continue Reading

Former Swiss Banker Pleads Guilty to Conspiring with U.S. Taxpayers and Other Swiss Bankers to Defraud the United States

On June 22, Michele Bergantino, a former banker at Credit Suisse AG, pled guilty in the Eastern District of Virginia to conspiring to defraud the United States by assisting American taxpayers to conceal foreign accounts and evade U.S. taxes.  Bergantino, who oversaw a portfolio of approximately $700 million in assets, attempted to avoid detection by facilitating discrete withdrawals of cash for his clients from Credit Suisse’s office in the Bahamas, removing information related to account ... Continue Reading

Two Cayman Island Financial Institutions Plead Guilty to Hiding Assets

In the first conviction of a non-Swiss financial institution for tax evasion conspiracy, two affiliated Cayman Island financial institutions, Cayman National Securities Ltd. (“CNS”) and Cayman National Trust Co. Ltd. (“CNT”), pled guilty on March 9 to conspiring with many of their U.S. taxpayer-clients to hide more than $130 million in offshore accounts from the IRS and evade related U.S. income taxes.  The offense conduct continued from 2001 to 2011, and, according to the information ... Continue Reading

Criminal Charges Filed Against Bank Julius Baer of Switzerland with Deferred Prosecution Agreement Requiring Payment of $547 Million, as Well as Guilty Pleas of Two Julius Baer Bankers

On February 4, Zurich-based Bank Julius Baer & Company entered into a DPA, agreeing to pay $547 million and admitting that it knowingly assisted many of its U.S. taxpayer clients in evading their tax obligations under U.S. law. Two of the bank’s financial advisors, Daniela Casadei and Fabio Frazzetto, pleaded guilty to conspiring to help U.S. taxpayers hide their assets in offshore accounts.  Both individuals had been previously charged in 2011 but remained at large ... Continue Reading

Justice Department Reaches its Final Three Resolutions under Category 2 of its Swiss Bank Program

The Justice Department ended this phase of its Swiss Bank Program, which, since March 30, 2015, has provided a path for 80 Swiss banks to resolve potential criminal liability in the United States. The Department has imposed a total of more than $1.36 billion in penalties under the Program.  In exchange for complying with certain requirements, including complete disclosure of possible tax-related criminal offenses in connection with undeclared U.S.-related accounts, the banks entered into non-prosecution ... Continue Reading

28 Banks Reach Resolutions Under Justice Department’s Swiss Bank Program

In November and December, 28 banks reached resolutions under DOJ’s Swiss Bank Program.  Since 2013, the Swiss Bank Program has provided a path for Swiss banks to resolve potential criminal liability in the United States.  In exchange for complying with certain requirements, including complete disclosure of possible tax-related criminal offenses in connection with undeclared U.S.-related accounts, the banks entered into NPAs with DOJ.  Under the NPAs, each bank must cooperate in related criminal or ... Continue Reading

Seven Banks Reach Resolutions Under Justice Department’s Swiss Bank Program

In September and October, a total of 15 banks reached resolutions under DOJ’s Swiss Bank Program.  Since 2013, the Swiss Bank Program has provided a path for Swiss banks to resolve potential criminal liability in the United States.  In exchange for complying with certain requirements, including complete disclosure of possible tax-related criminal offenses in connection with undeclared U.S.-related accounts, the banks entered into NPAs with DOJ.  Under the NPAs, each bank must cooperate in related ... Continue Reading

Seven Banks Reach Resolutions under Justice Department’s Swiss Bank Program

In August, a total of seven banks reached resolutions under DOJ’s Swiss Bank Program.  Since 2013, the Swiss Bank Program has provided a path for Swiss banks to resolve potential criminal liability in the United States.  In exchange for complying with certain requirements, including complete disclosure of possible tax-related criminal offenses in connection with undeclared U.S.-related accounts, the banks entered into non-prosecution agreements (“NPAs”) with DOJ.  Under the NPAs, each bank must cooperate in related ... Continue Reading

Eleven Banks Reach Resolutions under DOJ’s Swiss Bank Program

In July, a total of eleven banks reached resolutions under DOJ’s Swiss Bank Program.  Since 2013, the Swiss Bank Program has provided a path for Swiss banks to resolve potential criminal liabilities in the United States.  In exchange for complying with certain requirements, including complete disclosure of possible tax-related criminal offenses in connection with undeclared U.S.-related accounts, the banks entered into non-prosecution agreements (“NPAs”) with DOJ.  Under the NPAs, each bank must cooperate in related ... Continue Reading

Seven Banks Reach Resolutions under DOJ’s Swiss Bank Program

In June, seven banks reached resolutions under DOJ’s Swiss Bank Program.  The Swiss Bank Program provides an opportunity for Swiss banks to resolve potential criminal liabilities in the United States by disclosing possible tax-related criminal offenses in connection with undeclared U.S.-related accounts.  If a bank makes a complete disclosure and complies with other requirements of the program, it may enter into an NPA with DOJ.  Under the NPAs, each bank must cooperate in related criminal ... Continue Reading

Vadian Bank AG Reaches Resolution Under Department of Justice Swiss Bank Program

On May 8, Switzerland-based Vadian Bank AG (“Vadian”), reached a resolution with DOJ’s Swiss Bank Program.  Announced in 2013, the Swiss Bank Program allows eligible Swiss banks to resolve potential criminal liability in the United States regarding tax-related offenses for undeclared U.S. accounts.  In the resolution, Vadian agreed to cooperate in criminal or civil proceedings, demonstrate its implementation of controls to stop misconduct involving undeclared U.S. accounts, and pay a $4,253,000 penalty, in exchange for ... Continue Reading

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