The Department of Justice and local United States Attorneys\u2019
\nOffices continue to zealously prosecute numerous cases involving U.S. taxpayers
\nwho have failed to report their interests in offshore accounts. The successful
\nprosecutions underscore the government\u2019s aggressive investigations and enhanced
\nscrutiny. U.S. taxpayers who have failed to report their interests in offshore
\naccounts should consider voluntary disclosures and the pending IRS OVDI program.<\/p>\n
Below is a summary of many of the cases brought
\nsince February 2009:<\/p>\n
United States v. Harry Abrahamsen<\/em><\/strong>, United States v. Lucille Abrahamsen United States v. Jack Barouh<\/em><\/strong>, United States v. Josephine Bhasin<\/em><\/strong>, United States v. Bradley Birkenfeld<\/em><\/strong>, United States v. Jeffrey Chatfield<\/em><\/strong>, United States v. Jeffrey Chernick<\/em><\/strong>, United States v. Roberto Cittadini<\/em><\/strong>, United States v. Mauricio Cohen Assor United States v. Vaibhav Dahake<\/em><\/strong>, United States v. Arthur Joel Eisenberg<\/em><\/strong>, United States v. Renzo Gadola<\/em><\/strong>, United States v. Bernard Goldstein<\/em><\/strong>, United States v. Edward Gurary<\/em><\/strong>, United States v. Kenneth Heller<\/em><\/strong>, United States v. Federico Hernandez<\/em><\/strong>, United States v. Juergen Homann<\/em><\/strong>, United States v. John McCarthy<\/em><\/strong>, United States v. Felix Mathis<\/em><\/strong>, United States v. Robert Moran<\/em><\/strong>, United States v. Jules Robbins<\/em><\/strong>, United States v. Steven Michael United States v. Gregory Rudolph<\/em><\/strong>, United States v. Peter Schober<\/em><\/strong>, United States v. Hansreudi Schumacher United States v. Andrew Silva<\/em><\/strong>, United States v. Shmuel Sternfeld<\/em><\/strong>, United States v. Sybil Nancy Upham<\/em><\/strong>, United States v. Samuel Phineas Upham<\/em><\/strong>, United States v. Ernest Vogliano<\/em><\/strong>, United States v. Richard Werdiger<\/em><\/strong>, United States v. Paul Zabczuk<\/em><\/strong>, United States v. Leonid Zaltsberg<\/em><\/strong>, The Department of Justice and local United States Attorneys\u2019 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\u2019s aggressive investigations and enhanced scrutiny. U.S. taxpayers who have failed to report their interests in offshore accounts should consider voluntary […]<\/p>\n","protected":false},"author":1,"featured_media":0,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"_daextam_enable_autolinks":"","_monsterinsights_skip_tracking":false,"_monsterinsights_sitenote_active":false,"_monsterinsights_sitenote_note":"","_monsterinsights_sitenote_category":0,"footnotes":""},"categories":[1],"tags":[19,20,23,24,55,52,63,25,56,27],"class_list":["post-1254","post","type-post","status-publish","format-standard","hentry","category-planning-for-tax-minimization","tag-amnesty","tag-asset-protection","tag-fbar","tag-foreign-account","tag-hsbc","tag-offshore","tag-ovdi","tag-penalties-and-interest","tag-tax-crime","tag-voluntary-disclosure"],"_links":{"self":[{"href":"https:\/\/patellawoffices.com\/blog\/wp-json\/wp\/v2\/posts\/1254","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/patellawoffices.com\/blog\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/patellawoffices.com\/blog\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/patellawoffices.com\/blog\/wp-json\/wp\/v2\/users\/1"}],"replies":[{"embeddable":true,"href":"https:\/\/patellawoffices.com\/blog\/wp-json\/wp\/v2\/comments?post=1254"}],"version-history":[{"count":0,"href":"https:\/\/patellawoffices.com\/blog\/wp-json\/wp\/v2\/posts\/1254\/revisions"}],"wp:attachment":[{"href":"https:\/\/patellawoffices.com\/blog\/wp-json\/wp\/v2\/media?parent=1254"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/patellawoffices.com\/blog\/wp-json\/wp\/v2\/categories?post=1254"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/patellawoffices.com\/blog\/wp-json\/wp\/v2\/tags?post=1254"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}
\n10-00254 (D.N.J.): <\/strong>On April 12, 2010, Abrahamsen pleaded
\nguilty to one count of willful failure to file an FBAR under 31 U.S.C. \u00a7\u00a7 5314
\nand 5322. Abrahamsen admitted that he willfully failed to file a foreign bank
\naccount report and that he understated his income by exaggerating business
\nexpenses paid to a Swiss company, and that he deposited approximately $1.3
\nmillion into two bank accounts at UBS. Abrahamsen is scheduled to be sentenced
\non May 24, 2011.<\/p>\n
\nJackson<\/em><\/strong>, 10-00797 (D.N.J.): <\/strong>On
\nNovember 18, 2010, Ms. Jackson, who is the daughter of Harry Abrahamsen (see
\n<\/em>above), pleaded guilty to willfully subscribing to a false tax return after
\nadmitting that her 2005 tax return failed to disclose her UBS account and the
\nincome generated therefrom. The account, which was worth approximately
\n$750,000, was originally opened in 1992 and then transferred in 2000 to a nominee
\nPanamanian corporation. Jackson and her father established the Panamanian corporation
\nwith the assistance of a foreign lawyer and a Swiss banker. Jackson is
\nscheduled to be sentenced on May 23, 2011.<\/p>\n
\n10-20034 (S.D. Fla.): <\/strong>On April 23, 2010, Barouh, who had pleaded
\nguilty in February 2010 to one count of subscribing to a false federal income
\ntax return, was sentenced to ten months\u2019 imprisonment. Barouh admitted to
\nfailing to report his interest over, and income earned from, UBS bank accounts,
\nwhich he held in the names of sham Panamanian and British Virgin Island
\ncorporations. Barouh further admitted that these accounts, and others, were
\nfunded with skimmed income from his watch business, and that in 2007, with the
\nassistance of a Swiss attorney, he attempted to repatriate the funds by forming
\na new account in Hong Kong in the name of a Hong Kong corporation to pay him
\nbogus consulting fees. From 2002-2007, the tax loss associated with these
\naccounts was approximately $736,269, and the highest value of the offshore
\nassets was approximately $10 million.<\/p>\n
\n11-00268 (E.D.N.Y.): <\/strong>On April 13, 2011, Bhasin pleaded guilty
\nto filing a false tax return for the year 2008. Bhasin owned accounts at HSBC
\nin India that, in 2008, were valued at approximately $8.3 million, and
\ngenerated approximately $168,000 in income that she failed to report on her
\nreturn. In addition to charges related to her 2008 return, Bhasin admitted to
\nfiling false FBARs in 2007, 2008, and 2009, and a false amended tax return for
\nthe year 2009. <\/em><\/strong><\/p>\n
\n08-60099 (S.D. Fla.): <\/strong>On August 21, 2009, former UBS banker
\nBradley Birkenfeld was sentenced to 40 months in prison. On June 19, 2008,
\nBirkenfeld pleaded guilty to one count of conspiracy to defraud the U.S. In the
\nsentencing, the government argued that pursuant to U.S.S.G. \u00a7 5K1.1, the court
\nshould impose a below-Guidelines sentence of 30 months in prison (as opposed to
\n57-60 months) on account of Birkenfeld\u2019s substantial cooperation, which led to
\nover 150 criminal investigations, including those of Raoul Weil, Robert Moran,
\nSteven Michael Rubenstein, Jeffrey Chernick, and John McCarthy. Birkenfeld reported
\nto prison on January 8, 2010. Birkenfeld also has applied for a whistle-blower
\nreward for the taxes and penalties collected as a result of his cooperation. <\/em><\/strong><\/p>\n
\n10-CR-4546 (S.D. Cal.): <\/strong>On November 17, 2010, Chatfield pleaded
\nguilty to a criminal information charging him with filing a false tax return
\nrelated to an undeclared UBS account. With the assistance of a UBS banker,
\nChatfield opened a bank account at UBS Bahamas Ltd. in the name of a nominee
\nentity. Chatfield deposited into the account approximately $900,000 in untaxed
\nsecurities and cash that he received from his consulting work. In August 2002,
\nChatfield closed this account, formed a new Bahamian nominee entity, and opened
\na new account at another large global Swiss bank headquartered in Zurich, to
\nwhich he transferred the assets from the Bahamian account. On March 14, 2011,
\nChatfield received a sentence of 3 years probation. <\/em><\/strong><\/p>\n
\n09-60182 (S.D. Fla.): <\/strong>On October 30, 2009, Chernick was sentenced
\nto three months in prison, six months house arrest, and six months probation.
\nOn July 28, 2009, Chernick entered a guilty plea to one count of willfully
\nsubscribing to a false federal income tax return. Beginning in 1981, Chernick
\nhad off-shore accounts at UBS and another Swiss Bank in which he hid
\ncommissions paid by his Hong Kong and Chinese clients in order to avoid U.S.
\ntax. In addition, Chernick admitted to paying a $45,000 bribe to a Swiss
\nofficial to obtain information on the U.S.\u2019s investigation into UBS. The
\ngovernment requested a sentencereduction of fifty percent from the bottom of
\nthe sentencing guideline range of 18 to 24 months due to his cooperation with
\nits investigation into UBS. <\/em><\/strong><\/p>\n
\n09-344-RSM (W.D. Wash.): <\/strong>On October 5, 2009, Cittadini pleaded
\nguilty to one count of subscribing to a false federal return under 26 U.S.C. \u00a7
\n7206(1), admitting that he failed to report income from approximately $2
\nmillion held offshore in two UBS accounts. Cittadini also failed to file FBAR\u2019s
\nand admitted that he transferred his assets to a Hong Kong company to avoid
\ndetection by the U.S. In January 2010, Cittadini was sentenced to six months of
\nhome confinement and one year of supervised released. <\/em><\/strong><\/p>\n
\nand Leon Cohen-Levy<\/em><\/strong>, 10-CR-60159 (S.D. Fla.): <\/strong>On
\nApril 15, 2010, authorities arrested Assor and Cohen-Levy, father and son, for
\ncharges related to unreported foreign accounts and the use of allegedly sham
\noff-shore entities to conceal income from their real estate development
\nbusiness. The foreign accounts at issue were at HSBC. A superseding indictment
\nwas issued on August 3, 2010, charging both father and son with criminal
\nconspiracy, and charging Cohen-Levy with three counts of willfully subscribing
\nto a false federal income tax returns, and Cohen Assor with two counts of
\nwillfully subscribing to a false federal income tax returns. Cohen Assor and
\nCohen-Levy were detained after their April 15 arrest, and demanded a speedy
\ntrial. Trial began on September 13, 2010. On October 6, 2010, Cohen Assor was
\nfound guilty on all three counts, and Cohen-Levy was found guilty on the
\nconspiracy count and on two counts of willfully subscribing to a fake federal
\nreturn, but was found not guilty on a third count of willfully subscribing to a
\nfalse federal return. On February 4, 2011, Cohen Assor and Cohen-Levy were both
\nsentenced to 10 years in prison and fined $100,000. Cohen Assor was ordered to
\npay restitution of $9.4 million, and Cohen-Levy was ordered to pay restitution
\nof $7.8 million. Both father and son have filed appeals (Cohen Assor 11-10729-F,
\nCohen-Levy 11-10731-F) to the 11th Circuit. The two
\nappeals have been consolidated. <\/em><\/strong><\/p>\n
\n11-00042 (D. N.J.): <\/strong>On April 11, 2011, Dahake pleaded guilty
\nto one count of conspiracy to defraud the U.S. Dahake held undeclared accounts
\nat HSBC in India and at another bank in the British Virgin Islands through a
\nbearer share corporation. Dahake is scheduled to be sentenced on July 22, 2011.
\n <\/em><\/strong><\/p>\n
\n10-00369 (W.D. Wash.): <\/strong>On December 17, 2010, Eisenberg
\npleaded guilty to one count of filing a false tax return. Eisenberg had opened
\nan account at UBS in the Cayman Islands which he later transferred to an
\naccount at UBS in Switzerland. The highest balance of the accounts was $4.2
\nmillion in 2004. In 2008 Eisenberg closed his UBS account and transferred the
\nfunds to another Swiss bank. On March 4, 2011, he was sentenced to three years\u2019
\nprobation and a $25,000 fine. He also agreed to pay an FBAR penalty of $2.1
\nmillion. Prosecutors had recommended a 6-month prison sentence and 6 months of
\nhouse arrest because of Eisenberg\u2019s cooperation, his old age, the fact that he
\ndid not attempt to launder money or hide withdrawals and tried to make a
\nvoluntary disclosure. <\/em><\/strong><\/p>\n
\n10-CR-20878 (S.D. Fla.): <\/strong>On December 22, 2010, former UBS banker
\nRenzo Gadola pleaded guilty to conspiring to defraud the U.S. Gadola was a
\nregistered investment advisor with the SEC, and a private banker at UBS AG from
\napproximately 1995through August 2008. In February 2009, Gadola began working
\nat an independent investment advisement firm, RG Investment Partner AG. Gadola
\nwas arrested in Miami after meeting with a client to attempt to persuade the
\nclient not to disclose an account at Basler Kantonalbank in Basel, Switzerland.
\nThe account was funded with over $445,000 in cash that the client gave to Gadola\u2019s
\npartner during meetings in New Orleans. Gadola attempted to persuade the client
\nnot to disclose the account, claiming that here was no \u201cpaper trail\u201d and that
\nit was unlikely that the U.S. government would discover it. The sentencing
\nscheduled for April 26, 2011 was adjourned. <\/em><\/strong><\/p>\n
\n10-CR-04576 (S.D. Cal.): <\/strong>Goldstein was indicted on November
\n19, 2010 for conspiracy to defraud the IRS, filing false tax returns, and
\nfailing to file FBAR\u2019s with respect to accounts at UBS. Goldstein is a Canadian
\ncitizen and lawful permanent resident of the U.S. Goldstein opened a UBS bank
\naccount in his own name in 1992 with assets that were worth approximately $2
\nmillion by the end of 2000. In 2000, he transferred the funds in this account
\nto a new UBS account opened under the name of a sham Panamanian Corporation.
\nGoldstein also maintained an account at UBS Cayman Islands Ltd. until 2002, when
\nhe transferred assets held in that account to the Swiss UBS account. In 2004,
\nGoldstein transferred these funds to an account at another large global Swiss
\nbank in Zurich. Goldstein entered a guilty plea on November 30, 2010. <\/em><\/strong><\/p>\n
\n11-00072 (W.D. Wash.): <\/strong>On March 8, 2011, Gurary pleaded guilty
\nto filing false tax returns for the years 2004 to 2008. Gurary held an
\nunreported account at UBS in the name of a Bahamanian company and another
\naccount at Credit Suisse. Gurary is scheduled to be sentenced on June 1, 2011. <\/em><\/strong><\/p>\n
\n10-CR-00388 (S.D.N.Y.): <\/strong>On April 15, 2010, a criminal complaint
\nwas filed against Heller, a disbarred maritime attorney. It is alleged that
\nHeller opened a UBS account in the name of sham corporation and deposited $26.4
\nmillion into the account. Heller allegedly failed to report the account, and in
\n2008, after learning through a news article that UBS might turn over
\ninformation about account holders to the U.S., Heller allegedly moved his funds
\nto a smaller private bank in Switzerland that did not have offices in the U.S. After
\na hearing, Heller was found competent to stand trial, and on March 24, the
\ngovernment filed a superseding indictment. <\/em><\/strong><\/p>\n
\n10-CR-00334 (S.D.N.Y.): <\/strong>On April 15, 2010, Hernandez pleaded
\nguilty to five counts of subscribing to a false tax return, and agreed to pay a
\ncivil FBAR penalty of $4.4 million. In 2001 and 2006, Hernandez opened UBS
\naccounts in the names of sham Panamanian and British Virgin Islands
\ncorporations, and failed to report his interest in, or the income from, those
\naccounts. On September 17, 2010, Hernandez was sentenced to concurrent terms of
\nimprisonment of 12 months and 1 day for each of the five counts, and was ordered
\nto pay restitution of $84,423. <\/em><\/strong><\/p>\n
\n2009-CR-00724 (D. N.J.): <\/strong>On January 6, 2010, Juergen Homann,
\na New Jersey businessman who pleaded guilty in September 2009 to one count of willful
\nfailure to file a report of foreign financial accounts with a value of more
\nthan $6.1 million under 31 U.S.C. \u00a7\u00a7 5314 and 5322, was sentenced to five years
\nprobation, 300 hours of community service, and a $60,000 fine. Although the
\ncourt criticized Homann as having beenmotivated by greed, it noted that the
\nlenient sentence was warranted because Homann provided the U.S. government with
\n\u201csubstantial and significant assistance.\u201d <\/em><\/strong><\/p>\n
\n09-00784 (C.D. Cal.): <\/strong>On August 14, 2009, McCarthy entered
\na guilty plea to one count of willfully failing to file an FBAR. The criminal
\ncomplaint alleges that McCarthy had skimmed money from his domestic business
\nand funneled it into a Hong Kong entity which held an account at UBS. McCarthy
\ntransferred $1 million into the UBS account, and failed to pay approximately
\n$200,000 in tax. On March 22, 2010, McCarthy was sentenced to three years of
\nprobation and a $25,000 fine. <\/em><\/strong><\/p>\n
\n1:10-CR-260 (E.D. Va.): <\/strong>On July 15, 2010, a Swiss attorney
\nand member of the New York State Bar, was indicted on one count of conspiracy
\nto defraud the U.S. under 18 U.S.C. \u00a7 371 and two counts of assisting in the
\nstructuring of the importation of financial instruments under 31 U.S.C. \u00a7\u00a7
\n5324(c)(3) and (d)(2). The indictment alleged that Mathis helped U.S. clients
\nmaintain secret accounts in Switzerland by setting up Liechtenstein Trusts, and
\nthat he aided his clients in illegally sending their funds to the U.S.
\nSpecifically, the Indictment alleges that Mathis assisted Andrew Silva, a
\nclient of Mathis who was sentenced this summer (see <\/em>below), in hiding
\nassets. In addition, the Indictment alleges that Mathis assisted another client
\nin closing her account and withdrawing $115,000 in cash, which he helped package
\nin envelopes each containing less than $10,00 for mailing to the U.S. <\/em><\/strong><\/p>\n
\n09-60089 (S.D. Fla.): <\/strong>On November 6, 2009, Moran was sentenced
\nto two months in prison and one year of probation, including 150 days of house
\narrest. Moran pleaded guilty in April 2009 to one count of willfully
\nsubscribing to a false return pursuant to 26 U.S.C. \u00a7 7206(1). Moran controlled
\na Panamanian corporation that held UBS accounts with assets valued at
\napproximately $3.4 million that he used to trade in U.S. and European
\nsecurities. The government argued for a reduced sentence based on his \u201ctimely, significant,
\nand complete assistance to the government,\u201d and in imposing the sentence, the
\ncourt also noted that Moran had paid $1.9 million to the government in back
\ntaxes, interest, and penalties. <\/em><\/strong><\/p>\n
\n10-CR-00333 (S.D.N.Y.): <\/strong>On April 15, 2010, Robbins pleaded guilty
\nto five counts of willfully subscribing to a false tax return. Robbins had
\naccounts at UBS since 1967, and in 2000, he set up a sham Hong Kong corporation
\nto hold his UBS account. Robbins also consented to pay a civil FBAR penalty of
\n$20.8 million, an amount equal to 50% of the highest value of his UBS accounts
\nfor the years in which he failed to file FBAR\u2019s. Robbins also pleaded guilty in
\nNew York County criminal court, and was sentenced to a conditional discharge
\nafter paying $859,699 in New York State taxes, interest, and penalties. On
\nSeptember 21, 2010, Robbins\u2019 was sentenced to one year of probation on the
\nfederal charges. <\/em><\/strong><\/p>\n
\nRubenstein<\/em><\/strong>, 09-60166 (S.D. Fla.): <\/strong>On
\nOctober 28, 2009, Rubenstein was sentenced to three years of probation, with 1
\nyear of house arrest, and a $40,000 fine. Rubenstein pleaded guilty in June
\n2009 to one count of willfully subscribing to a false return. Rubenstein had
\nworked with UBS bankers to transfer funds in and out of UBS accounts held by a
\nnominee British Virgin Islands corporation and repatriated $7 million for the
\npurchase of property and to build a personal residence in Boca Raton. The
\ngovernment requested a reduction in Rubenstein\u2019s sentence due to his
\nsubstantial assistance with its investigation of UBS\u2019s offshore banking
\nactivities. <\/em><\/strong><\/p>\n
\n10-10360 (D. Mass.): <\/strong>On February 23, 2011, Rudolph pleaded
\nguilty to one count of failing to file an FBAR. Rudolph, a real estate developer,
\nopened an account in his own name at UBS in 2000, and in 2001, Rudolph created
\nanother account at UBS in the name of British Virgin Islands shell corporation
\nand transferred the money from his other UBS account into it. In 2005, Rudolph
\ntransferred the funds into yet another UBS account registered in the name of a
\nHong Kong shell corporation. During this time, he used the funds for his own
\nbenefit by transferring them to an account owned by a family member as well as
\nto a domestic shell corporation. Sentencing is scheduled for November 17, 2011.
\n <\/em><\/strong><\/p>\n
\n10-10259 (D. Mass.): <\/strong>On November 23, 2010, Schober pleaded guilty
\nto one count of failing to file an FBAR. In 2002, Schober, an investment
\nmanager, opened an account at UBS in the name of a Panamanian corporation with
\nno operations. He deposited in excess of $1 million in income and from other
\nexisting accounts into this account. Schober filed FBARs for another foreign
\naccount but failed to report the existence of his UBS account. Sentencing is
\nscheduled for August 11, 2011. <\/em><\/strong><\/p>\n
\nand Mathias Rickenbach<\/em><\/strong>, 09-60210 (S.D. Fla.):
\n<\/strong>On
\nAugust 21, 2009, Schumacher, a former head of UBS\u2019 cross-border business, and a
\nprivate banker and executive manager at Neu Zuercher Bank (\u201cNZB\u201d), and
\nRickenbach, a Swiss attorney, were charged with aiding U.S. clients in hiding
\nincome and assets in offshore accounts. The indictment describes Schumacher and
\nRickenbach\u2019s involvement with John McCarthy and Jeffrey Chernick and two other
\nunnamed clients who held accounts at UBS and later NZB. As of December 10,
\n2009, the case has been suspended until the defendants, who are both fugitives,
\nare apprehended. <\/em><\/strong><\/p>\n
\n10-CR-00044-LO-1 (E.D. Va.): <\/strong>On February 16, 2010,
\nSilva pleaded guilty to one count of conspiracy to defraud the U.S. under 18
\nU.S.C. \u00a7 371, and making a false statement under 18 U.S.C. \u00a7 1001(a)(1). Silva,
\nwho had inherited a Swiss bank account from his mother held in the name of a
\nLiechtenstein trust, met with a Swiss attorney, who assisted him in keeping the
\naccount secret from the U.S. In September 2009, after being informed that the
\nbank was closing his account, Silva made two trips to Zurich, and withdrew $235,000
\nin U.S. currency, which he mailed in 26 packages to the United States. Upon his
\nreturn to the United States, Silva falsely informed a U.S. Customs Inspector
\nthat he had traveled to Switzerland to purchase diamonds and that had not
\nrecently mailed any U.S. currency from Switzerland into the U.S. In addition,
\nSilva had not reported his interest in, or income from, the foreign account on
\nhis tax returns and he failed to file FBAR\u2019s. On June 11, 2010, Silva was sentenced
\nto two years\u2019 probation with four months of home detention with electronic monitoring
\nand was fined $20,000. He was also ordered to pay restitution of $16,484 and
\n100 hours of community service. He also agreed to forfeit the $211,200 in U.S.
\ncurrency that law enforcement officials seized from the packages mailed from
\nSwitzerland to Virginia. <\/em><\/strong><\/p>\n
\n10-CR-00328 (S.D.N.Y.): <\/strong>In an indictment unsealed on April
\n15, 2010, Sternfeld, of Tel Aviv, Israel, was with one count of conspiring to
\ndefraud the IRS, one count of willfully subscribing to a false federal income
\ntax return, and five counts of willful failure to file an FBAR. The indictment
\nalleges that in 2004, Sternfeld opened a UBS account in the name of a Hong Kong
\nshell corporation, and between June 2004 and June 2008, transferred hundreds of
\nthousands of dollars from that account to a bank account in the Czech Republic.
\nThe indictment further alleges that Sternfeld transferred money from the UBS
\naccount to make a down payment on a Florida condominium. According to the
\nindictment, at the end of 2005, the UBS account held nearly $2.9 million. After
\nlearning about the investigation into UBS\u2019 cross-border business in 2008,
\nSternfeld transferred the funds in the UBS account to a small Swiss bank that
\ndid not have offices in the U.S. Sternfeld remains at large. <\/em><\/strong><\/p>\n
\n10-CR-00326 (S.D.N.Y.): <\/strong>On November 10, 2010, Upham pleaded
\nguilty to one count of conspiracy and three counts of subscribing to a false federal
\nincome tax return. In 1993, Upham opened a UBS account in the name of a sham Liechtenstein
\nfoundation, and in 2000, signed UBS documents instructing the bank that she \u201cwould
\nlike to avoid disclosure of [her] identity to the US Internal Revenue Service
\nunder the new tax regulations.\u201d In 2005, Upham opened a second UBS account in
\nthe name of a sham Hong Kong corporation, again to conceal her ownership
\ninterest. In May 2008, after learning about the investigation into UBS\u2019
\ncross-border business, Upham began to move her funds from UBS into a smaller
\nLiechtenstein bank that did not have offices in the U.S. The indictment alleges
\nthat Upham transferred over $8.5 million from UBS to the Liechtenstein bank and
\nevaded approximately $750,000 in federal income taxes. <\/em><\/strong><\/p>\n
\n10-CR-1028 (S.D.N.Y.): <\/strong>On December 7, 2010, a grand jury
\nin the Southern District of New York indicted Upham on charges of conspiring to
\ndefraud the IRS and aiding in the preparation of fraudulent tax returns. The
\nindictment alleges that Mr. Upham is a close family member of an unnamed former
\nclient of UBS, who appears to be Sybil Nancy Upham (see <\/em>above). Mr.
\nUpham stood to inherit one-third of the assets in one of the UBS accounts upon
\nMs. Upham\u2019s death. Mr. Upham is alleged to have smuggled $450,000 in cash from
\nMs. Upham\u2019s accounts at UBS in Zurich to the U.S., $14,500 of which was deposited
\ninto one of his New York bank accounts. Mr. Upham also exchanged e-mails with UBS
\nregarding transfers of funds in May 2008, after which Ms. Upham transferred
\nmore than $8.5 million from UBS to a Liechtenstein bank. Mr. Upham also
\nprepared Ms. Upham\u2019s Forms 1040 for 2005-2007. Motions are due in the case on
\nMay 11, 2011. <\/em><\/strong><\/p>\n
\n<\/em>10-CR-00327
\n(S.D.N.Y.): <\/strong>On December 22, 2010, Vogliano pleaded
\nguilty to one count of conspiring to defraud the IRS and five counts of
\nsubscribing to false federal income tax returns. In 2000 and 2002, Vogliano
\nopened UBS accounts in the names of Lichtenstein and Hong Kong shell
\ncorporations. As of December 31, 2000, he held approximately $4.9 million at
\nUBS. Moreover, after learning about the investigation into UBS\u2019 cross-border
\nbusiness, Vogliano transferred his funds from UBS to a Liechtenstein bank that
\ndid not have offices in the U.S. Vogliano regularly travelled to UBS\u2019 offices
\nin Zurich and obtained hundreds of thousands of dollars in travelers\u2019 checks,
\nand on at least one occasion, he mailed the checks in separate envelopes to
\nhimself in New York. On April 21, 2011, Vogliano was sentenced to two years of
\nprobation and was assessed approximately $950,000 in fines and penalties.<\/p>\n
\n10-CR-00325 (S.D.N.Y.): <\/strong>In an indictment unsealed on April
\n15, 2010, Werdiger was charged with having opened three UBS accounts under the
\nnames of sham foundations and corporations formed in Liechtenstein and Panama.
\nThe indictment further alleges that to conceal his ownership of these accounts,
\nWerdiger instructed UBS to communicate with him using the code name \u201cTrygon.\u201d
\nThe government alleged that as of December 31, 2003, the account contained over
\n$7 million. On March 11, 2011, Werdiger pleaded guilty to one count of
\nconspiring to defraud the IRS, five counts of willfully subscribing to a false
\nfederal income tax return. Sentencing is scheduled for June 14, 2011. <\/em><\/strong><\/p>\n
\n10-60112 (S.D. Fla.): <\/strong>On July 27, 2010, Zabczuk was
\nsentenced to three years of probation including one year of house arrest. He
\nwas also sentenced to 150 hours of community service and was ordered to pay
\n$832,000 in taxes, interest and penalties plus a fine of $25,000. Zabczuk
\npleaded guilty to one count of filing a false tax return on April 13, 2010. Zabczuk
\nhad accounts in the Bahamas and at UBS in Switzerland that were funded with unreported
\ncommissions and skimmed income. In 2009, he tried to hide the funds by transferring
\nthem to another offshore bank. The highest value of these accounts was approximately
\n$529,194. Zabczuk repatriated some of these funds by withdrawing cash. The government
\nrequested a downward departure because Zabczuk cooperated with their ongoing investigation
\ninto Swiss Banks. <\/em><\/strong><\/p>\n
\n2:2010-CR-00437 (D.N.J.): <\/strong>On July 1, 2010, Zaltzberg pleaded
\nguilty to one count of willfully subscribing to a false federal income tax
\nreturn, admitting that for the 2003 tax year, he signed and filed a false tax
\nreturn that did not disclose his UBS account or the income generated from that
\naccount. Zaltsberg also admitted that he underreported his income from the UBS
\naccount from 2000-2006, and that the account at one point had over $2.6
\nmillion. On December 20, 2010 Zaltsberg was sentenced to four years of probation
\nincluding one year of location monitoring.<\/p>\n","protected":false},"excerpt":{"rendered":"