In April, the IRS got a court's permission to serve John Doe summonses to Wells Fargo & Co as part of an offshore tax evasion investigation.
With John Doe summonses, "what the U.S. is trying to do is figure out who accessed their undeclared Swiss bank account money, and did anyone access it in a way that flowed through U.S. banks," said Jeffrey Neiman, a former federal prosecutor involved in Swiss bank investigations who is now in private law practice in Fort Lauderdale, Florida.
Banking secrecy is enshrined in Swiss law and tradition but has recently come under pressure as the United States and other nations have moved aggressively to tighten tax law enforcement and demand more openness and cooperation.
The case is In the Matter of the Tax Liabilities of John Does, U.S. District Court, Southern District of New York, No. 13-mc-378.
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