Last week the U.S. Justice Department asked a federal district court in San Francisco to…
Numerous Criminal Prosecutions of Taxpayers with Unreported Offshore Accounts
The Department of Justice and local United States Attorneys’
Offices continue to zealously prosecute numerous cases involving U.S. taxpayers
who have failed to report their interests in offshore accounts. The successful
prosecutions underscore the government’s aggressive investigations and enhanced
scrutiny. U.S. taxpayers who have failed to report their interests in offshore
accounts should consider voluntary disclosures and the pending IRS OVDI program.
Below is a summary of many of the cases brought
since February 2009:
United States v. Harry Abrahamsen,
10-00254 (D.N.J.): On April 12, 2010, Abrahamsen pleaded
guilty to one count of willful failure to file an FBAR under 31 U.S.C. §§ 5314
and 5322. Abrahamsen admitted that he willfully failed to file a foreign bank
account report and that he understated his income by exaggerating business
expenses paid to a Swiss company, and that he deposited approximately $1.3
million into two bank accounts at UBS. Abrahamsen is scheduled to be sentenced
on May 24, 2011.
United States v. Lucille Abrahamsen
Jackson, 10-00797 (D.N.J.): On
November 18, 2010, Ms. Jackson, who is the daughter of Harry Abrahamsen (see
above), pleaded guilty to willfully subscribing to a false tax return after
admitting that her 2005 tax return failed to disclose her UBS account and the
income generated therefrom. The account, which was worth approximately
$750,000, was originally opened in 1992 and then transferred in 2000 to a nominee
Panamanian corporation. Jackson and her father established the Panamanian corporation
with the assistance of a foreign lawyer and a Swiss banker. Jackson is
scheduled to be sentenced on May 23, 2011.
United States v. Jack Barouh,
10-20034 (S.D. Fla.): On April 23, 2010, Barouh, who had pleaded
guilty in February 2010 to one count of subscribing to a false federal income
tax return, was sentenced to ten months’ imprisonment. Barouh admitted to
failing to report his interest over, and income earned from, UBS bank accounts,
which he held in the names of sham Panamanian and British Virgin Island
corporations. Barouh further admitted that these accounts, and others, were
funded with skimmed income from his watch business, and that in 2007, with the
assistance of a Swiss attorney, he attempted to repatriate the funds by forming
a new account in Hong Kong in the name of a Hong Kong corporation to pay him
bogus consulting fees. From 2002-2007, the tax loss associated with these
accounts was approximately $736,269, and the highest value of the offshore
assets was approximately $10 million.
United States v. Josephine Bhasin,
11-00268 (E.D.N.Y.): On April 13, 2011, Bhasin pleaded guilty
to filing a false tax return for the year 2008. Bhasin owned accounts at HSBC
in India that, in 2008, were valued at approximately $8.3 million, and
generated approximately $168,000 in income that she failed to report on her
return. In addition to charges related to her 2008 return, Bhasin admitted to
filing false FBARs in 2007, 2008, and 2009, and a false amended tax return for
the year 2009.
United States v. Bradley Birkenfeld,
08-60099 (S.D. Fla.): On August 21, 2009, former UBS banker
Bradley Birkenfeld was sentenced to 40 months in prison. On June 19, 2008,
Birkenfeld pleaded guilty to one count of conspiracy to defraud the U.S. In the
sentencing, the government argued that pursuant to U.S.S.G. § 5K1.1, the court
should impose a below-Guidelines sentence of 30 months in prison (as opposed to
57-60 months) on account of Birkenfeld’s substantial cooperation, which led to
over 150 criminal investigations, including those of Raoul Weil, Robert Moran,
Steven Michael Rubenstein, Jeffrey Chernick, and John McCarthy. Birkenfeld reported
to prison on January 8, 2010. Birkenfeld also has applied for a whistle-blower
reward for the taxes and penalties collected as a result of his cooperation.
United States v. Jeffrey Chatfield,
10-CR-4546 (S.D. Cal.): On November 17, 2010, Chatfield pleaded
guilty to a criminal information charging him with filing a false tax return
related to an undeclared UBS account. With the assistance of a UBS banker,
Chatfield opened a bank account at UBS Bahamas Ltd. in the name of a nominee
entity. Chatfield deposited into the account approximately $900,000 in untaxed
securities and cash that he received from his consulting work. In August 2002,
Chatfield closed this account, formed a new Bahamian nominee entity, and opened
a new account at another large global Swiss bank headquartered in Zurich, to
which he transferred the assets from the Bahamian account. On March 14, 2011,
Chatfield received a sentence of 3 years probation.
United States v. Jeffrey Chernick,
09-60182 (S.D. Fla.): On October 30, 2009, Chernick was sentenced
to three months in prison, six months house arrest, and six months probation.
On July 28, 2009, Chernick entered a guilty plea to one count of willfully
subscribing to a false federal income tax return. Beginning in 1981, Chernick
had off-shore accounts at UBS and another Swiss Bank in which he hid
commissions paid by his Hong Kong and Chinese clients in order to avoid U.S.
tax. In addition, Chernick admitted to paying a $45,000 bribe to a Swiss
official to obtain information on the U.S.’s investigation into UBS. The
government requested a sentencereduction of fifty percent from the bottom of
the sentencing guideline range of 18 to 24 months due to his cooperation with
its investigation into UBS.
United States v. Roberto Cittadini,
09-344-RSM (W.D. Wash.): On October 5, 2009, Cittadini pleaded
guilty to one count of subscribing to a false federal return under 26 U.S.C. §
7206(1), admitting that he failed to report income from approximately $2
million held offshore in two UBS accounts. Cittadini also failed to file FBAR’s
and admitted that he transferred his assets to a Hong Kong company to avoid
detection by the U.S. In January 2010, Cittadini was sentenced to six months of
home confinement and one year of supervised released.
United States v. Mauricio Cohen Assor
and Leon Cohen-Levy, 10-CR-60159 (S.D. Fla.): On
April 15, 2010, authorities arrested Assor and Cohen-Levy, father and son, for
charges related to unreported foreign accounts and the use of allegedly sham
off-shore entities to conceal income from their real estate development
business. The foreign accounts at issue were at HSBC. A superseding indictment
was issued on August 3, 2010, charging both father and son with criminal
conspiracy, and charging Cohen-Levy with three counts of willfully subscribing
to a false federal income tax returns, and Cohen Assor with two counts of
willfully subscribing to a false federal income tax returns. Cohen Assor and
Cohen-Levy were detained after their April 15 arrest, and demanded a speedy
trial. Trial began on September 13, 2010. On October 6, 2010, Cohen Assor was
found guilty on all three counts, and Cohen-Levy was found guilty on the
conspiracy count and on two counts of willfully subscribing to a fake federal
return, but was found not guilty on a third count of willfully subscribing to a
false federal return. On February 4, 2011, Cohen Assor and Cohen-Levy were both
sentenced to 10 years in prison and fined $100,000. Cohen Assor was ordered to
pay restitution of $9.4 million, and Cohen-Levy was ordered to pay restitution
of $7.8 million. Both father and son have filed appeals (Cohen Assor 11-10729-F,
Cohen-Levy 11-10731-F) to the 11th Circuit. The two
appeals have been consolidated.
United States v. Vaibhav Dahake,
11-00042 (D. N.J.): On April 11, 2011, Dahake pleaded guilty
to one count of conspiracy to defraud the U.S. Dahake held undeclared accounts
at HSBC in India and at another bank in the British Virgin Islands through a
bearer share corporation. Dahake is scheduled to be sentenced on July 22, 2011.
United States v. Arthur Joel Eisenberg,
10-00369 (W.D. Wash.): On December 17, 2010, Eisenberg
pleaded guilty to one count of filing a false tax return. Eisenberg had opened
an account at UBS in the Cayman Islands which he later transferred to an
account at UBS in Switzerland. The highest balance of the accounts was $4.2
million in 2004. In 2008 Eisenberg closed his UBS account and transferred the
funds to another Swiss bank. On March 4, 2011, he was sentenced to three years’
probation and a $25,000 fine. He also agreed to pay an FBAR penalty of $2.1
million. Prosecutors had recommended a 6-month prison sentence and 6 months of
house arrest because of Eisenberg’s cooperation, his old age, the fact that he
did not attempt to launder money or hide withdrawals and tried to make a
voluntary disclosure.
United States v. Renzo Gadola,
10-CR-20878 (S.D. Fla.): On December 22, 2010, former UBS banker
Renzo Gadola pleaded guilty to conspiring to defraud the U.S. Gadola was a
registered investment advisor with the SEC, and a private banker at UBS AG from
approximately 1995through August 2008. In February 2009, Gadola began working
at an independent investment advisement firm, RG Investment Partner AG. Gadola
was arrested in Miami after meeting with a client to attempt to persuade the
client not to disclose an account at Basler Kantonalbank in Basel, Switzerland.
The account was funded with over $445,000 in cash that the client gave to Gadola’s
partner during meetings in New Orleans. Gadola attempted to persuade the client
not to disclose the account, claiming that here was no “paper trail” and that
it was unlikely that the U.S. government would discover it. The sentencing
scheduled for April 26, 2011 was adjourned.
United States v. Bernard Goldstein,
10-CR-04576 (S.D. Cal.): Goldstein was indicted on November
19, 2010 for conspiracy to defraud the IRS, filing false tax returns, and
failing to file FBAR’s with respect to accounts at UBS. Goldstein is a Canadian
citizen and lawful permanent resident of the U.S. Goldstein opened a UBS bank
account in his own name in 1992 with assets that were worth approximately $2
million by the end of 2000. In 2000, he transferred the funds in this account
to a new UBS account opened under the name of a sham Panamanian Corporation.
Goldstein also maintained an account at UBS Cayman Islands Ltd. until 2002, when
he transferred assets held in that account to the Swiss UBS account. In 2004,
Goldstein transferred these funds to an account at another large global Swiss
bank in Zurich. Goldstein entered a guilty plea on November 30, 2010.
United States v. Edward Gurary,
11-00072 (W.D. Wash.): On March 8, 2011, Gurary pleaded guilty
to filing false tax returns for the years 2004 to 2008. Gurary held an
unreported account at UBS in the name of a Bahamanian company and another
account at Credit Suisse. Gurary is scheduled to be sentenced on June 1, 2011.
United States v. Kenneth Heller,
10-CR-00388 (S.D.N.Y.): On April 15, 2010, a criminal complaint
was filed against Heller, a disbarred maritime attorney. It is alleged that
Heller opened a UBS account in the name of sham corporation and deposited $26.4
million into the account. Heller allegedly failed to report the account, and in
2008, after learning through a news article that UBS might turn over
information about account holders to the U.S., Heller allegedly moved his funds
to a smaller private bank in Switzerland that did not have offices in the U.S. After
a hearing, Heller was found competent to stand trial, and on March 24, the
government filed a superseding indictment.
United States v. Federico Hernandez,
10-CR-00334 (S.D.N.Y.): On April 15, 2010, Hernandez pleaded
guilty to five counts of subscribing to a false tax return, and agreed to pay a
civil FBAR penalty of $4.4 million. In 2001 and 2006, Hernandez opened UBS
accounts in the names of sham Panamanian and British Virgin Islands
corporations, and failed to report his interest in, or the income from, those
accounts. On September 17, 2010, Hernandez was sentenced to concurrent terms of
imprisonment of 12 months and 1 day for each of the five counts, and was ordered
to pay restitution of $84,423.
United States v. Juergen Homann,
2009-CR-00724 (D. N.J.): On January 6, 2010, Juergen Homann,
a New Jersey businessman who pleaded guilty in September 2009 to one count of willful
failure to file a report of foreign financial accounts with a value of more
than $6.1 million under 31 U.S.C. §§ 5314 and 5322, was sentenced to five years
probation, 300 hours of community service, and a $60,000 fine. Although the
court criticized Homann as having beenmotivated by greed, it noted that the
lenient sentence was warranted because Homann provided the U.S. government with
“substantial and significant assistance.”
United States v. John McCarthy,
09-00784 (C.D. Cal.): On August 14, 2009, McCarthy entered
a guilty plea to one count of willfully failing to file an FBAR. The criminal
complaint alleges that McCarthy had skimmed money from his domestic business
and funneled it into a Hong Kong entity which held an account at UBS. McCarthy
transferred $1 million into the UBS account, and failed to pay approximately
$200,000 in tax. On March 22, 2010, McCarthy was sentenced to three years of
probation and a $25,000 fine.
United States v. Felix Mathis,
1:10-CR-260 (E.D. Va.): On July 15, 2010, a Swiss attorney
and member of the New York State Bar, was indicted on one count of conspiracy
to defraud the U.S. under 18 U.S.C. § 371 and two counts of assisting in the
structuring of the importation of financial instruments under 31 U.S.C. §§
5324(c)(3) and (d)(2). The indictment alleged that Mathis helped U.S. clients
maintain secret accounts in Switzerland by setting up Liechtenstein Trusts, and
that he aided his clients in illegally sending their funds to the U.S.
Specifically, the Indictment alleges that Mathis assisted Andrew Silva, a
client of Mathis who was sentenced this summer (see below), in hiding
assets. In addition, the Indictment alleges that Mathis assisted another client
in closing her account and withdrawing $115,000 in cash, which he helped package
in envelopes each containing less than $10,00 for mailing to the U.S.
United States v. Robert Moran,
09-60089 (S.D. Fla.): On November 6, 2009, Moran was sentenced
to two months in prison and one year of probation, including 150 days of house
arrest. Moran pleaded guilty in April 2009 to one count of willfully
subscribing to a false return pursuant to 26 U.S.C. § 7206(1). Moran controlled
a Panamanian corporation that held UBS accounts with assets valued at
approximately $3.4 million that he used to trade in U.S. and European
securities. The government argued for a reduced sentence based on his “timely, significant,
and complete assistance to the government,” and in imposing the sentence, the
court also noted that Moran had paid $1.9 million to the government in back
taxes, interest, and penalties.
United States v. Jules Robbins,
10-CR-00333 (S.D.N.Y.): On April 15, 2010, Robbins pleaded guilty
to five counts of willfully subscribing to a false tax return. Robbins had
accounts at UBS since 1967, and in 2000, he set up a sham Hong Kong corporation
to hold his UBS account. Robbins also consented to pay a civil FBAR penalty of
$20.8 million, an amount equal to 50% of the highest value of his UBS accounts
for the years in which he failed to file FBAR’s. Robbins also pleaded guilty in
New York County criminal court, and was sentenced to a conditional discharge
after paying $859,699 in New York State taxes, interest, and penalties. On
September 21, 2010, Robbins’ was sentenced to one year of probation on the
federal charges.
United States v. Steven Michael
Rubenstein, 09-60166 (S.D. Fla.): On
October 28, 2009, Rubenstein was sentenced to three years of probation, with 1
year of house arrest, and a $40,000 fine. Rubenstein pleaded guilty in June
2009 to one count of willfully subscribing to a false return. Rubenstein had
worked with UBS bankers to transfer funds in and out of UBS accounts held by a
nominee British Virgin Islands corporation and repatriated $7 million for the
purchase of property and to build a personal residence in Boca Raton. The
government requested a reduction in Rubenstein’s sentence due to his
substantial assistance with its investigation of UBS’s offshore banking
activities.
United States v. Gregory Rudolph,
10-10360 (D. Mass.): On February 23, 2011, Rudolph pleaded
guilty to one count of failing to file an FBAR. Rudolph, a real estate developer,
opened an account in his own name at UBS in 2000, and in 2001, Rudolph created
another account at UBS in the name of British Virgin Islands shell corporation
and transferred the money from his other UBS account into it. In 2005, Rudolph
transferred the funds into yet another UBS account registered in the name of a
Hong Kong shell corporation. During this time, he used the funds for his own
benefit by transferring them to an account owned by a family member as well as
to a domestic shell corporation. Sentencing is scheduled for November 17, 2011.
United States v. Peter Schober,
10-10259 (D. Mass.): On November 23, 2010, Schober pleaded guilty
to one count of failing to file an FBAR. In 2002, Schober, an investment
manager, opened an account at UBS in the name of a Panamanian corporation with
no operations. He deposited in excess of $1 million in income and from other
existing accounts into this account. Schober filed FBARs for another foreign
account but failed to report the existence of his UBS account. Sentencing is
scheduled for August 11, 2011.
United States v. Hansreudi Schumacher
and Mathias Rickenbach, 09-60210 (S.D. Fla.):
On
August 21, 2009, Schumacher, a former head of UBS’ cross-border business, and a
private banker and executive manager at Neu Zuercher Bank (“NZB”), and
Rickenbach, a Swiss attorney, were charged with aiding U.S. clients in hiding
income and assets in offshore accounts. The indictment describes Schumacher and
Rickenbach’s involvement with John McCarthy and Jeffrey Chernick and two other
unnamed clients who held accounts at UBS and later NZB. As of December 10,
2009, the case has been suspended until the defendants, who are both fugitives,
are apprehended.
United States v. Andrew Silva,
10-CR-00044-LO-1 (E.D. Va.): On February 16, 2010,
Silva pleaded guilty to one count of conspiracy to defraud the U.S. under 18
U.S.C. § 371, and making a false statement under 18 U.S.C. § 1001(a)(1). Silva,
who had inherited a Swiss bank account from his mother held in the name of a
Liechtenstein trust, met with a Swiss attorney, who assisted him in keeping the
account secret from the U.S. In September 2009, after being informed that the
bank was closing his account, Silva made two trips to Zurich, and withdrew $235,000
in U.S. currency, which he mailed in 26 packages to the United States. Upon his
return to the United States, Silva falsely informed a U.S. Customs Inspector
that he had traveled to Switzerland to purchase diamonds and that had not
recently mailed any U.S. currency from Switzerland into the U.S. In addition,
Silva had not reported his interest in, or income from, the foreign account on
his tax returns and he failed to file FBAR’s. On June 11, 2010, Silva was sentenced
to two years’ probation with four months of home detention with electronic monitoring
and was fined $20,000. He was also ordered to pay restitution of $16,484 and
100 hours of community service. He also agreed to forfeit the $211,200 in U.S.
currency that law enforcement officials seized from the packages mailed from
Switzerland to Virginia.
United States v. Shmuel Sternfeld,
10-CR-00328 (S.D.N.Y.): In an indictment unsealed on April
15, 2010, Sternfeld, of Tel Aviv, Israel, was with one count of conspiring to
defraud the IRS, one count of willfully subscribing to a false federal income
tax return, and five counts of willful failure to file an FBAR. The indictment
alleges that in 2004, Sternfeld opened a UBS account in the name of a Hong Kong
shell corporation, and between June 2004 and June 2008, transferred hundreds of
thousands of dollars from that account to a bank account in the Czech Republic.
The indictment further alleges that Sternfeld transferred money from the UBS
account to make a down payment on a Florida condominium. According to the
indictment, at the end of 2005, the UBS account held nearly $2.9 million. After
learning about the investigation into UBS’ cross-border business in 2008,
Sternfeld transferred the funds in the UBS account to a small Swiss bank that
did not have offices in the U.S. Sternfeld remains at large.
United States v. Sybil Nancy Upham,
10-CR-00326 (S.D.N.Y.): On November 10, 2010, Upham pleaded
guilty to one count of conspiracy and three counts of subscribing to a false federal
income tax return. In 1993, Upham opened a UBS account in the name of a sham Liechtenstein
foundation, and in 2000, signed UBS documents instructing the bank that she “would
like to avoid disclosure of [her] identity to the US Internal Revenue Service
under the new tax regulations.” In 2005, Upham opened a second UBS account in
the name of a sham Hong Kong corporation, again to conceal her ownership
interest. In May 2008, after learning about the investigation into UBS’
cross-border business, Upham began to move her funds from UBS into a smaller
Liechtenstein bank that did not have offices in the U.S. The indictment alleges
that Upham transferred over $8.5 million from UBS to the Liechtenstein bank and
evaded approximately $750,000 in federal income taxes.
United States v. Samuel Phineas Upham,
10-CR-1028 (S.D.N.Y.): On December 7, 2010, a grand jury
in the Southern District of New York indicted Upham on charges of conspiring to
defraud the IRS and aiding in the preparation of fraudulent tax returns. The
indictment alleges that Mr. Upham is a close family member of an unnamed former
client of UBS, who appears to be Sybil Nancy Upham (see above). Mr.
Upham stood to inherit one-third of the assets in one of the UBS accounts upon
Ms. Upham’s death. Mr. Upham is alleged to have smuggled $450,000 in cash from
Ms. Upham’s accounts at UBS in Zurich to the U.S., $14,500 of which was deposited
into one of his New York bank accounts. Mr. Upham also exchanged e-mails with UBS
regarding transfers of funds in May 2008, after which Ms. Upham transferred
more than $8.5 million from UBS to a Liechtenstein bank. Mr. Upham also
prepared Ms. Upham’s Forms 1040 for 2005-2007. Motions are due in the case on
May 11, 2011.
United States v. Ernest Vogliano,
10-CR-00327
(S.D.N.Y.): On December 22, 2010, Vogliano pleaded
guilty to one count of conspiring to defraud the IRS and five counts of
subscribing to false federal income tax returns. In 2000 and 2002, Vogliano
opened UBS accounts in the names of Lichtenstein and Hong Kong shell
corporations. As of December 31, 2000, he held approximately $4.9 million at
UBS. Moreover, after learning about the investigation into UBS’ cross-border
business, Vogliano transferred his funds from UBS to a Liechtenstein bank that
did not have offices in the U.S. Vogliano regularly travelled to UBS’ offices
in Zurich and obtained hundreds of thousands of dollars in travelers’ checks,
and on at least one occasion, he mailed the checks in separate envelopes to
himself in New York. On April 21, 2011, Vogliano was sentenced to two years of
probation and was assessed approximately $950,000 in fines and penalties.
United States v. Richard Werdiger,
10-CR-00325 (S.D.N.Y.): In an indictment unsealed on April
15, 2010, Werdiger was charged with having opened three UBS accounts under the
names of sham foundations and corporations formed in Liechtenstein and Panama.
The indictment further alleges that to conceal his ownership of these accounts,
Werdiger instructed UBS to communicate with him using the code name “Trygon.”
The government alleged that as of December 31, 2003, the account contained over
$7 million. On March 11, 2011, Werdiger pleaded guilty to one count of
conspiring to defraud the IRS, five counts of willfully subscribing to a false
federal income tax return. Sentencing is scheduled for June 14, 2011.
United States v. Paul Zabczuk,
10-60112 (S.D. Fla.): On July 27, 2010, Zabczuk was
sentenced to three years of probation including one year of house arrest. He
was also sentenced to 150 hours of community service and was ordered to pay
$832,000 in taxes, interest and penalties plus a fine of $25,000. Zabczuk
pleaded guilty to one count of filing a false tax return on April 13, 2010. Zabczuk
had accounts in the Bahamas and at UBS in Switzerland that were funded with unreported
commissions and skimmed income. In 2009, he tried to hide the funds by transferring
them to another offshore bank. The highest value of these accounts was approximately
$529,194. Zabczuk repatriated some of these funds by withdrawing cash. The government
requested a downward departure because Zabczuk cooperated with their ongoing investigation
into Swiss Banks.
United States v. Leonid Zaltsberg,
2:2010-CR-00437 (D.N.J.): On July 1, 2010, Zaltzberg pleaded
guilty to one count of willfully subscribing to a false federal income tax
return, admitting that for the 2003 tax year, he signed and filed a false tax
return that did not disclose his UBS account or the income generated from that
account. Zaltsberg also admitted that he underreported his income from the UBS
account from 2000-2006, and that the account at one point had over $2.6
million. On December 20, 2010 Zaltsberg was sentenced to four years of probation
including one year of location monitoring.
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