John Doe Summons

The Department of Justice just announced that various United States federal courts have entered orders authorizing the Internal Revenue Service to serve so-called “John Doe summonses” on eighteen US banks and financial institutions. The John Doe summonses are seeking information about persons who have used specific credit or debit cards in Norway. The cards were issued by various US banks and it is highly suspected that the Norwegian citizens who set up the US accounts to which they relate were not in compliance with Norwegian tax laws.

A “John Doe Summons” is a very powerful weapon against tax evasion. It generally directs a financial institution (e.g., here, a US bank, such as Prairie Sun Bank with offices in Minnesota, for example) to produce records identifying certain persons (here, all Norwegian persons) having current or closed accounts at the institution. The summons need not identify any individual by name – the general description (e.g., all Norwegian citizens) is enough! Indeed, the John Doe summons has helped IRS catch many US tax evaders who were using offshore accounts in Switzerland, India, and Lichtenstein etc.

Norway Finding Tax Evaders In The US With IRS’ Help

The DOJ announcement provides that the Norwegian authorities have reason to believe, based upon the use of payment cards in Norway that were issued by U.S. banks, that unidentified card holders may have failed to report financial account information or income on their Norwegian tax returns. Court papers cite examples where individuals Read More