IRS Authorized to Issue Summonses To US Citizens with Offshore Bank Accounts

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bankruptcy -Five Banks Directed to Produce Records for Accounts at Zurcher Kantonalbank, The Bank of N.T. Butterfield & Son Limited, and Their Affiliates
Preet Bharara, the United States Attorney for the Southern District of New York, Kathryn Keneally, the Assistant Attorney General for the Justice Department’s Tax Division, and Danny Werfel, the Acting Commissioner of the Internal Revenue Service (“IRS”), announced today that U.S. District Judge Kimba M. Wood entered an order on November 7, 2013, authorizing the IRS to issue summonses requiring Bank of New York Mellon (“Mellon”) and Citibank, NA (“Citibank”), to produce information about U.S. taxpayers who may be evading or have evaded federal taxes by holding interests in undisclosed accounts at Zurcher Kantonalbank and its affiliates (collectively, “ZKB”) in Switzerland; and U.S. District Judge Richard M. Berman entered an order today authorizing the IRS to issue summonses requiring Mellon, Citibank, JPMorgan Chase Bank, NA (“JPMorgan”), HSBC Bank USA, NA (“HSBC”), and Bank of America, NA (“Bank of America”), to produce similar information in connection with undisclosed accounts at The Bank of N.T. Butterfield & Son Limited and its affiliates (collectively, “Butterfield”) in the Bahamas, Barbados, Cayman Islands, Guernsey, Hong Kong, Malta, Switzerland, and the United Kingdom. 


In these actions, the Court granted the IRS permission to serve what are known as “John Doe” summonses on Mellon, Citibank, JPMorgan, HSBC, and Bank of America.  The IRS uses John Doe summonses to obtain information about possible tax fraud by individuals whose identities are unknown. 

The John Doe summonses direct these five banks to produce records identifying U.S. taxpayers with accounts at ZKB, Butterfield, and their affiliates, including other foreign banks that used ZKB and Butterfield’s U.S. correspondent accounts at Mellon, Citibank, JPMorgan, HSBC, and Bank of America to service U.S. clients.



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