TaxProf Blog

Editor: Paul L. Caron, Dean
Pepperdine University School of Law

Monday, November 18, 2013

IRS Issues 'John Doe' Summonses to Five Banks Over Offshore Accounts

Wall Street Journal:  Targeting Offshore Accounts, by Laura Saunders:

In a fresh assault on undeclared offshore accounts, two federal courts have approved the issuing of summonses to five U.S. banks in connection with transfers made on behalf of two foreign banks, officials announced this week 

Citigroup's Citibank unit and Bank of New York Mellon have been ordered to turn over information about U.S. taxpayers who might have evaded taxes by holding undisclosed accounts at Switzerland's Zuercher Kantonalbank, or ZKB.

Citibank, J.P. Morgan Chase, HSBC Holdings ' HSBC Bank USA and Bank of America have been ordered to turn over similar information in connection with accounts held at the Bank of N.T. Butterfield & Son and its affiliates in the Bahamas, Barbados, Cayman Islands, Guernsey, Hong Kong, Malta, Switzerland and the United Kingdom.

The "John Doe" summonses allow the IRS to obtain names or other information for taxpayers in a certain group, such as tax evaders holding secret offshore accounts, based on evidence that such a group could exist.

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