Posted on 03/15/2021 1:23:12 PM PDT by ransomnote
Audrey Strauss, United States Attorney for the Southern District of New York, Stuart M. Goldberg, Acting Deputy Assistant Attorney General for the Department of Justice’s Tax Division, and James C. Lee, Chief of the Internal Revenue Service-Criminal Investigation (“IRS-CI”), announced the filing of a criminal Information against RAHN+BODMER CO. (“R+B”), a financial institution located in Zurich, Switzerland. The Information charges R+B with one count of conspiring to help U.S. accountholders evade their U.S. tax obligations, file false federal tax returns, and otherwise defraud the Internal Revenue Service (“IRS”) by hiding hundreds of millions of dollars in offshore bank accounts at R+B.
Ms. Strauss, Mr. Goldberg, and Mr. Lee also announced a deferred prosecution agreement with R+B (the “Agreement”), under which R+B admits to its unlawful conduct in assisting U.S. accountholders in violating their legal duties. R+B’s admissions are contained in a detailed Statement of Facts attached to the Agreement. The Agreement requires R+B to provide ongoing assistance to the Department of Justice and to pay a total of $22 million in restitution, forfeiture, and penalties. If R+B abides by all of the terms of the Agreement, the Government will defer prosecution on the Information for three years and then seek to dismiss the charge.
Manhattan U.S. Attorney Audrey Strauss said: “As Rahn+Bodmer now admits, it aided U.S. taxpayers in evading their tax responsibilities to the tune of more than $16 million. This venerated banking institution knowingly offered banking services that assisted its U.S. customers in evading their tax obligations, and affirmatively schemed to conceal from the IRS the assets and income of U.S. accountholders. Now Rahn+Bodmer will pay $22 million and commit to helping the Justice Department uncover tax evasion by U.S. customers.”
Acting Deputy Assistant Attorney General Stuart M. Goldberg said: “Under today’s resolution, Rahn+Bodmer is paying $22 million for helping U.S. accountholders evade their taxes, and has agreed to fully cooperate with investigations into those taxpayers. With the April 15 tax filing date fast approaching, there is a clear message for those intending not to pay their fair share – nothing remains hidden forever.”
IRS-CI Chief James C. Lee said: “Through a years-long scheme, the R+B bank hid the assets of U.S. accountholders to shield them from their tax obligations. Today’s admission and agreement provide a clear path to recovery of funds owed to the U.S. government, and sends a strong signal that offshore accounts are not beyond the reach of special agents with IRS CI.”
According to the Agreement, the accompanying Statement of Facts, and other documents filed today in Manhattan federal court:
From at least in or about 2004 and continuing until at least in or about 2012, R+B conspired with certain of its U.S. accountholders and others to defraud the United States with respect to taxes, file false federal tax returns, and commit tax evasion. R+B’s bankers assisted U.S. accountholders in concealing their ownership and control of assets and funds held in undeclared R+B accounts, which enabled those U.S. accountholders to evade their U.S. tax obligations. R+B admitted to holding undeclared accounts on behalf of approximately 340 U.S. taxpayers, who collectively evaded approximately $16.4 million in U.S. taxes between in or about 2004 and in or about 2012. The assets under management that R+B held for undeclared U.S. accountholders increased from approximately $391 million in 2004 to approximately $550 million in 2007, its peak year for undeclared assets under management.
In furtherance of the scheme to help U.S. taxpayers hide assets from the IRS and evade taxes, R+B undertook the following actions, among others:
Under today’s resolution, R+B is required to cooperate fully with the Department of Justice and affirmatively disclose new information it may later uncover regarding U.S.-related accounts. R+B is also required to disclose information consistent with the Department’s Swiss Bank Program relating to accounts closed between January 1, 2009, and December 31, 2019.
As part of the resolution, R+B will pay a total of $22 million, which has three parts. First, R+B has agreed to pay $4.9 million in restitution to the IRS, which represents the estimated unpaid taxes resulting from R+B’s participation in the conspiracy. Second, R+B has agreed to forfeit $9.7 million to the United States, which represents the approximate gross fees that R+B earned on its undeclared U.S.-related accounts between 2004 and 2012. Finally, R+B has agreed to pay a penalty of $7.4 million. The penalty takes into consideration that R+B conducted a thorough internal investigation and provided a substantial volume of documents to the Department, as well as implemented remedial measures to protect against the use of its services for tax evasion in the future.
* * *
Ms. Strauss and Mr. Goldberg praised the outstanding work of IRS-CI. Ms. Strauss also thanked the Department of Justice’s Tax Division for their partnership on this case.
This case is being handled by the Complex Frauds and Cybercrime Unit of the United States Attorney’s Office for the Southern District of New York and the Department of Justice’s Tax Division. Assistant U.S. Attorney Olga I. Zverovich and Trial Attorney Ellen M. Quattrucci are in charge of the case.
Is this the same bank that Vince “The Bagman” Foster used to travel to from DC, before his untimely demise?
I believe the Swiss have to abide by the same accords the US does in terms of money laundering and tax evasion.
I know they can turn a blind eye to a lot of stuff—but Switzerland is not the haven it was in the last century.
In other news, water is wet and... wait... yes, we're hearing unconfirmed reports that The Pope is Catholic.
Bet 95% of all deposits come from the DC area.
We’ll never hear who important did it. Unless it’s
Anyone. Trump.
And since the accounts are all held by powerful Democrats, I suspect there will be a couple of “suicide by several shots to the back of the head while driving over a cliff while on fire” type incidents in the IRS and DOJ soon ...
Suppose a very rich Asian Businessman left Hong Kong 10 years ago because he had the foresight to see what was going to happen there today with the Communist take over.
Suppose he made all of his wealth from HK and then in 2009 MOVED a significant portion of his wealth to this particular Swiss Bank.
He then immigrated to the USA LEGALLY and moved the rest of his wealth to the USA and in 2020, became a US Citizen.
Does the IRS have claim to all the money he has in that Swiss Bank account seeing that the money was NEVER MADE in the USA?
How many members of Congre$$? Probably the same number as the one who have substantial $$$$ investments in China.
I, for one, am thankful that Switzerland maintains it’s independence and freedom of operation beyond the reach of the criminal and rapacious illegitimate, tyrannical junta in DC. A Swiss bank account may be the only way we now have to try to save our assets from the thieves in our own country. I have had an email account with ProtonMail based in Switzerland for years to provide secure communications outside the control of the political crooks in DC and the high-tech crooks in Silicon Valley.
And GOPee Delenda Est!
Good for them. the IRS is too intrusive as it is.
This reminds me of the Panama Papers incident from a few years ago. Big, Big news for a few days, then nothing.
No. The IRS taxes income, not previously and legally acquired capital.
Going to be a lot of congress persons taking flights this week got to keep the accounts moving when the heat gets to high.
and $16MM? really?? only $16MM??? pikers
RE: The IRS taxes income, not previously and legally acquired capital.
So, the interest earned from the Swiss bank account deposited BEFORE the individual became a US Citizen is taxable by the IRS?
I don’t believe so, unless he is a US resident. Say, with a Green Card, but not yet a citizen.
OK, Let’s make it more detailed ( but it is NOT theoretical because I know of such people ).
Mr. Wong is worth $20 million.
He deposited $10 Million of that in a Swiss Bank Account in 2010.
He applies for a Green card to the USA and was accepted after a few years.
He brings the remaining $10 Million to the USA in 2015 after migrating to the US as a permanent resident.
He becomes a US Citizen in 2020.
Between 2010 and 2020, His Swiss Deposits earns hundreds of thousands in interest, after 2020, his Swiss Bank account also earns interest.
Question: Are the interest from his Swiss Bank account during the time he became a US Permanent resident in 2015 ( money he made before he came to the US and never brought to the USA ), TAXABLE by the IRS?
I believe so, but I’m not certain. If the US considers you to be under it’s jurisdiction, I think it taxes worldwide income. Bit, if that interest was declared and taxed by a different authority, then the US would recognize the other country’s claim, and credit tax paid to the other country as an offset.
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