William Byrnes

A citizen and resident of Switzerland pleaded guilty today to conspiring to defraud the United States in connection with her work as the head of a team of bankers for Credit Suisse AG, announced Acting Deputy Assistant Attorney General Stuart M. Goldberg of the Justice Department’s Tax Division and U.S. Attorney Dana J. Boente for the Eastern District of Virginia. Read More

The Man Who Ended the Tradition of Bank Secrecy And Got Rich In The Process

Meet Bradley Birkenfield. Mr. Birkenfield, a former Swiss banker, was released from federal prison three years ago after serving 2½ years for helping wealthy American clients hide millions of dollars from the U.S. government. Five weeks after his release from prison, Birkenfield was sitting on his couch wallowing in his misery, recognizing that he was unemployable as a private banker anywhere. But little did he know that his fate was about to change. As he was devouring his third pint of “Ben and Jerry’s” Boom Chocolatta, there was a knock on the door. It was his lawyer. And his lawyer came bearing gifts — a big gift — one that would choke a horse. It was a check for $104 million dollars Read More

A combined fine of $225,000 and five years of unsupervised probation without jail time was handed down to two former bankers of Credit Suisse AG. Josef Dörig and Andreas Bachmann, both Swiss nationals, received the reduced sentence due to their cooperation with U.S. authorities.

Their crime: helping U.S. citizens evade taxes. Just one year ago, Credit Suisse pleaded guilty to “knowingly and willfully” assisting numerous American clients to commit tax evasion. How? By helping its U.S. clients open accounts and then hide the income generated by those accounts from the IRS. The penalty – which is considered to be the “cornerstone” of plea agreements when a company is the defendant in a tax evasion case – did not come without a price. In order to make “peace” with the U.S. government, Read More

Not On My Watch

When European financial giant Credit Suisse AG pleaded guilty to assisting U.S. taxpayers evade federal income tax, there was a great deal of swagger at the Justice Department. Former Attorney General Eric Holder, in classic Clint Eastwood style, boldly proclaimed that “no financial institution. . .is above the law,” and that any other bank which dared engage in such “brazen misconduct” would be “prosecut[ed] to the fullest extent possible.” Not to be outdone, Deputy AG James Cole warned investors that, if government investigators began asking questions, “[o]nly through full cooperation will you avoid the most severe sanctions.”

Tough words, indeed. But what is behind the Justice Department’s bravado, and what options do you have if you get a not-so-friendly phone call or if authorities suddenly Read More

Josef Dörig, 72, of Switzerland, pleaded guilty on April 30th to conspiring to defraud the Internal Revenue Service (IRS) in connection with his work as the owner of Dorig Partner AG, a trust company in Switzerland.

In a statement of facts filed with the plea agreement, Dörig admitted that between 1997 and 2011, while owning and operating a trust company, he engaged in a wide-ranging conspiracy to aid and assist U.S. customers in evading their income taxes by concealing assets and income in secret bank accounts held in the names of sham entities at Credit Suisse.  In 1997, the Credit Suisse subsidiary spun off these sham entities into a trust company, Dorig Partner AG, owned and operated by Dorig, the Justice Department said. Read More

Thousands of Credit Suisse Group AG’s United States clients still don’t know whether tax authorities will learn their identities as prosecutors work to conclude a three-year probe of how the bank helped them evade taxes.

We posted on February 27, 2014, Report to Congress: Credit Suisse Help US Taxpayers Hide Billions in Offshore Accounts! where we discussed the Permanent Subcommittee on Investigations (PSI) of the United States Senate held a hearing, “Offshore Tax Evasion: The Effort to Collect Unpaid Taxes on Billions in Hidden Offshore Accounts,” on Wednesday, February 26, 2014.

The PSI hearing’s stated purpose of continuing the PSI’s examination of tax haven bank Read More

Permanent Subcommittee on Investigations (PSI) of the United States Senate held a hearing, “Offshore Tax Evasion: The Effort to Collect Unpaid Taxes on Billions in Hidden Offshore Accounts,” on Wednesday, February 26, 2014, in Room G-50 of the Dirksen Senate Office Building.

The PSI hearing on February 26 is for the stated purpose of continuing the PSI’s examination of tax haven bank facilitation of U.S. tax evasion, focusing on the status of efforts to hold Swiss banks and their U.S. clients accountable for unpaid taxes on billions of dollars in hidden assets. Witnesses include representatives from Credit Suisse and the U.S. Department of Justice. Read More

iStock_Swiss-Bank-VaultXSmallThe Swiss government has cleared the way for a dozen banks to turn over client data to the IRS despite an earlier ruling from Switzerland’s Federal Supreme Court.

Although the IRS pushed the implementation of certain FATCA key deadlines from January 1st to July 1st, 2014, as we posted in IRS Delays FATCA Registration for Six Months, several Swiss banks are ready to turn over their records over to the IRS.

The Swiss Federal Court has dismissed protests by American clients of Credit Suisse that their account data should not be disclosed to the US Internal Revenue Service (IRS).

The IRS and Justice Department have become very adept at finding unreported offshore accounts. By targeting banks and individual bankers, the IRS is often able to leverage the threat of jail in return for cooperation and the release of customer records. The IRS also has several other tools in its arsenal.

On Tuesday, June 18, 2013, we posted DOJ Requests Identification of US Depositors in Bank Weglin – Time To Come Clean? where we discussed that the US Department of Justice has submitted another administrative assistance request to the Swiss authorities, this one demanding the identification of American clients of the private bank Wegelin who were beneficiaries of asset management companies between 2002 and 2012. Read More