http:\/\/www.irs.gov\/uac\/Offshore-Tax-Avoidance-and-IRS-Compliance-Efforts<\/p>\n
The IRS continues to uncover abusive tax-avoidance schemes involving offshore activity. Find information here pertaining to Union Bank of Switzerland (UBS).<\/p>\n
IRS to Receive Unprecedented Amount of Information in UBS Agreement<\/a> (News Release 2009-75)<\/p>\n Excerpts from IRS Commissioner Doug Shulman’s Press Remarks<\/a><\/p>\n U.S.-Swiss Government Agreement<\/a> | Declarations<\/a> | Bank Agreement<\/a><\/p>\n Feb. 18, 2015 \u2014 Georges Briguet<\/a> pleaded guilty to corruptly endeavoring to obstruct and impede the IRS. For tax years 2001 through 2010, Briguet filed false federal income tax returns on which he failed to report his foreign financial accounts, failed to report any income earned thereon and failed to pay any taxes on such foreign income.<\/p>\n Oct. 20, 2014 \u2014 Menasha Cohen<\/a>, from Hampton, N.H., pleaded guilty to filing a false income tax return for tax year 2009. Cohen, an oriental carpet dealer, and his sister maintained an undeclared bank account at UBS with a balance of approximately $1.3 million.<\/p>\n Oct. 14, 2014 \u2014 Gregg A. Kaminsky, a self-employed Internet entrepreneur, was indicted for failing to file a Report of Foreign Bank and Financial Accounts (FBAR) form and failing to disclose his UBS bank account.<\/p>\n Oct. 3, 2014 \u2014 Howard Bloomberg<\/a> pleaded guilty to willfully failing to disclose a foreign bank account he controlled at UBS.<\/p>\n June 18, 2014 \u2014 Gabriel Gabella<\/a> pleaded guilty to failing to file a Report of Foreign Bank and Financial Accounts (FBAR). In the plea agreement, Gabella agreed to pay a civil penalty of $3,140,346 and to pay $239,012 in restitution to the IRS.<\/p>\n May 27, 2014 \u2014 Martin Lack, a former UBS AG banker, was sentenced to five years of probation and ordered to pay a $7,500 fine. Lack was charged in August 2011<\/a> with conspiracy to defraud the United States.\u00a0He assisted U.S. customers to open and maintain secret bank accounts.<\/p>\n May 9, 2014 \u2014 Dr. Patricia Lynn Hough<\/a>, of Englewood, Fla, was sentenced to 24 months in prison for conspiring to defraud the IRS by concealing millions of dollars in assets and income in offshore bank accounts at UBS and other foreign banks, and for filing false individual income tax returns.\u00a0Hough was also ordered to pay $15,518,382 in restitution and $42,732 for the costs of prosecution.<\/p>\n March 21, 2014 \u2014 Victor Lipukhin<\/a>, formerly a resident of St. Charles, Ill., was indicted for attempting to interfere with the administration of the Internal Revenue laws and filing false tax returns. Lipukhin, a Russian citizen and former lawful permanent U.S. resident, kept between approximately $4,000,000 and $7,500,000 in assets in two bank accounts with UBS from at least 2002 through 2007.<\/p>\n March 18, 2014 \u2014 California attorney Christopher M. Rusch<\/a> was sentenced to 10 months in prison for helping his clients Stephen M. Kerr and Michael Quiel hide millions of dollars in secret offshore bank accounts. Rusch pleaded guilty on Feb. 6, 2013, to conspiracy to defraud the government and failing to file a Report of Foreign Bank and Financial Accounts (FBAR).<\/p>\n Feb. 26, 2014 \u2014 Christopher B. Berg<\/a>, of Portola Valley, Calif., was sentenced to one year and one day in prison. Prior to sentencing, Berg paid more than $250,000 in restitution to the IRS, as well as a penalty of $287,896 for failure to properly report his foreign account.<\/p>\n Jan. 14, 2014 \u2014 H. Ty Warner<\/a> was sentenced to two years\u2019 probation for tax evasion. Warner has paid more than $53 million in a civil penalty, as well as approximately $27 million in back taxes and interest.<\/p>\n Sept. 24, 2013 \u2014 Stephen M. Kerr and Michael Quiel were each sentenced to 10 months in prison.Stephen M. Kerr and Michael Quiel<\/a> were convicted of failing to disclose secret offshore bank accounts in Switzerland. Kerr and Quiel, prominent Phoenix businessmen, were each convicted of two counts of filing false individual income tax returns for 2007 and 2008. Kerr was also convicted of two counts of failing to file a Report of Foreign Bank and Financial Accounts (FBAR).<\/p>\n July 16, 2013 \u2014 Peter Troost<\/a>, of Skokie, Ill., was sentenced to 12 months and a day in prison for evading taxes on more than $3 million held in offshore UBS accounts. Troost has already paid over $1 million in back taxes, as well as a civil penalty of approximately $3.75 million.<\/p>\n April 25, 2013 \u2014 Mary Estelle Curran, of Palm Beach, Fla., was sentenced for filing false tax returns. Curran pleaded guilty in January 2013 and agreed to pay a civil penalty of $21 million.<\/p>\n Mar 21, 2013 \u2014 Rakesh Chitkara<\/a>, of Marlboro, N.J., pleaded guilty to filing false personal federal income tax returns. Chitkara must repay back taxes and pay a civil penalty of $839,885\u00a0for willfully failing to file Reports of Foreign Bank and Financial Accounts (FBARs) on at least two accounts at UBS AG in Zurich, Switzerland.<\/p>\n Jan. 30, 2013 \u2014 Christopher B. Berg<\/a> of Portola Valley, Calif., pleaded guilty today to willfully failing to file a Report of Foreign Bank and Financial Accounts (FBAR) for an account he controlled at UBS in the year 2005.<\/p>\n Oct. 11, 2012 \u2014 Wolfgang Roessel, of Fort Lauderdale, Fla., was sentenced to three years probation. Roessel pleaded guilty<\/a> in May 2012 to filing a false tax return and failing to file a Report of Foreign Bank and Financial Accounts (FBAR). The plea agreement includes a tax loss of more than $312,000 and an FBAR penalty owed of more than $5,750,000.<\/p>\n July 30, 2012 \u2014 Sean and Nadia Roberts<\/a>, of Tehachapi, Calif., were sentenced to 12 months and one day in prison for hiding millions of dollars in secret offshore bank accounts in Switzerland and other banks around the world. They were also ordered to pay $709,675 in restitution to the IRS and to pay more than $2.5 million in civil penalties failing to file Reports of Foreign Bank and Financial Accounts (FBARs).<\/p>\n July 25, 2012 \u2014 Luis A. Quintero, of Miami Beach, Fla., was sentenced to four months in prison and fined $20,000. Quintero also paid a $2 million civil penalty. Quintero pleaded guilty in April 2012 to willfully failing to file a Report of Foreign Bank and Financial Accounts (FBAR).<\/p>\n Mar. 29, 2012 \u2014 Lothar Hoess was sentenced to three years of probation and ordered to pay over $2 million in restitution for willfully failing to file a Report of Foreign Bank and Financial Accounts (FBAR).<\/p>\n Jan. 11, 2012\u00a0\u2014\u00a0Michael Reiss<\/a>, a doctor, professor and medical researcher, was sentenced to eight months in a community confinement center for failing to file Reports of Foreign Bank and Financial Accounts (FBAR) with the IRS. Reiss pleaded guilty in August 2011 and agreed to pay back taxes of at least $400,000 and to pay a civil penalty of over $1.2 million.<\/p>\n Dec. 7, 2011 \u2014 Amir Zavieh<\/a>, of San Francisco, Calif., was indicted with conspiring to defraud the Internal Revenue Service (IRS).\u00a0According to the indictment, Zavieh concealed a bank account at UBS by placing his domestic assets in the name of a nominee and failing to file income tax returns.<\/p>\n Nov. 9, 2011\u00a0\u2014\u00a0Robert E. Greeley<\/a>, of San Francisco, was sentenced to three years probation and ordered to pay $16,869 in restitution to the IRS.\u00a0In addition, Greeley will pay over $6.8 million in civil penalties and interest.\u00a0Greeley\u00a0pleaded guilty in August 2011 to charges of filing a false federal income tax return.\u00a0He concealed more than $13 million in two bank accounts he held with UBS AG.<\/p>\n Nov. 9, 2011 \u2014 Richard Werdiger, of Purchase, N.Y., was sentenced to one year and one day in prison for conspiring to defraud the IRS by hiding more than $7.1 million at UBS, filing false income tax returns and evading nearly $400,000 in taxes. In addition, Werdiger agreed to pay a civil penalty of over $3.8 million.<\/p>\n Oct. 5, 2011 \u2013 Peter Schober, of Boston, Mass., was sentenced to one month in prison and six months of supervised release, of which two months will be served in home confinement. Schober was also ordered to pay $77,870 in restitution and a $777,986 civil penalty.\u00a0In November 2010, Schober pleaded guilty to willfully failing to file a Report of Foreign Bank and Financial Accounts (FBAR) concealing over $1 million from the IRS.<\/p>\n July 14, 2011 \u2013 Anton Ginzburg<\/a> pleaded guilty to failing to file a Report of Foreign Bank and Financial Accounts (FBAR). Ginzburg agreed to pay a civil penalty of over $1.5 million.<\/p>\n June 27, 2011 \u2014 Kenneth Heller<\/a>, of New York, N.Y., pleaded guilty to income tax evasion. Heller admitted to hiding more than $26.4 million in a bank account at UBS AG and he has agreed to pay a civil penalty of over $9.8 million.<\/p>\n May 24, 2011 \u2014 Harry Abrahamsen<\/a>, of Oradell, N.J., was sentenced to three years probation, including 12 months of home confinement with electronic monitoring, and ordered to pay $600,000 in restitution to the Internal Revenue Service (IRS). In addition, Abrahamsen agreed to pay a civil penalty in excess of $300,000. In April 2010, Abrahamsen pleaded guilty to failure to file a (FBAR) report and admitted that he concealed over $1 million in Swiss bank accounts.<\/p>\n May 23, 2011 \u2014 Lucille Abrahamsen Jackson<\/a>, of Hilldale, N.J., was sentenced to one year probation. In addition, Jackson agreed to pay a civil penalty in excess of $379,000. Jackson pleaded guilty in November 2010 to filing a false tax return and failing to file a Report of Foreign Bank or Financial Account (FBAR). She admitted to concealing over $750,000 in a UBS account by transferring ownership of the account to a nominee Panamanian corporation.<\/p>\n April 21, 2011 \u2014 Ernest Vogliano<\/a>, of Manhattan, N.Y., was sentenced to two years probation and ordered to pay a $940,000 civil penalty. He pleaded guilty on Dec. 22, 2010, to filing false tax returns and conspiring to defraud the Internal Revenue Service\u00a0by hiding $4.9 million in an offshore bank account with UBS, AG.<\/p>\n March 14, 2011 \u2014 Jeffrey Chatfield<\/a>, of San Diego, Calif., was sentenced to three years\u2019 probation and ordered to pay more than $96,000 to resolve his civil liability with the IRS for failing to file the required Reports of Foreign Bank and Financial Reports (FBARs). Chatfield pleaded guilty<\/a>\u00a0on Nov. 18, 2010, to filing a false tax return in which he failed to report a UBS account containing $900,000.\u00a0Between 2000 and 2008, Chatfield transferred the $900,000 through several offshore accounts of nominee entities.<\/p>\n March 8, 2011\u00a0\u2014\u00a0Edward Gurary<\/a>, of Orange Village, Ohio, pleaded guilty to filing false income tax returns for the years 2004 through 2008. Gurary owned and controlled a financial account at UBS AG which was in the name of a Bahamian entity and failed to report interest income earned on his tax returns.<\/p>\n March 4, 2011\u00a0\u2014\u00a0Arthur Joel Eisenberg, of Seattle, Wash., was sentenced<\/a> to serve three years\u2019 probation and to pay a $2.1 million penalty for failing to file a Report of Foreign Bank or Financial Account (FBAR) form. Eisenberg pleaded\u00a0guilty\u00a0in December 2010 to willfully filing a false tax return which failed to report over $3.1 million in various UBS bank accounts.<\/p>\n Dec. 7, 2010 \u2014 Samuel Phineas Upham<\/a>, of New York, N.Y., was indicted conspiring with a family member to hide over $11 million in an offshore UBS bank account.\u00a0He also assisted in establishing a sham foundation in Liechtenstein to further conceal money from the IRS.<\/p>\n Nov. 19, 2010 \u2014 Bernard Goldstein, of Carlsbad, Calif., was indicted for conspiracy to defraud the IRS, filing false tax returns, and failing to file Report of Foreign Bank or Financial Accounts (FBARs). Goldstein is alleged to have transferred over $2 million in a UBS account to a sham Panamanian corporation in an effort to conceal the account from the IRS.<\/p>\n Nov. 10, 2010\u00a0\u2014\u00a0Sybil Nancy Upham, of Manhattan, N.Y., pleaded guilty to conspiring to defraud the IRS and subscribing to false federal income tax returns.\u00a0As part of her plea agreement, Upham has agreed to pay over $5.5 million in penalties for failure to file FBARs.\u00a0On April 15, 2010, Upham was indicted<\/a>\u00a0with five other individuals for hiding millions of dollars in secret Swiss bank accounts.<\/p>\n Oct. 4, 2010\u00a0\u2014 Gregory Rudolph, of Brookline, Mass., pleaded guilty to failing to comply with foreign bank account reporting requirements.\u00a0UBS bankers assisted Rudolph with creating a shell company registered in the British Virgin Islands and a shell corporation registered in Hong Kong in hiding in excess of $1 million.\u00a0In October 2010, Rudolph was indicted\u00a0with Peter Schober.<\/p>\n Sept. 21, 2010 \u2014 Jules Robbins<\/a>, of New York, N.Y., who owned and operated watch distribution companies, was sentenced to one year probation and ordered to pay a civil FBAR penalty of $20.8 million. Robbins set up a sham Hong Kong corporation which was listed as the holder of an UBS account in an effort to conceal his income from the IRS.\u00a0This account and Robbins’ other offshore accounts collectively contained almost $42 million in unreported income.<\/p>\n Sept. 17, 2010 \u2014 Federico Hernandez<\/a>, of New York, N.Y., was sentenced to 12 months in prison, six months home confinement,\u00a0and ordered to pay a civil FBAR penalty of $4.4 million.\u00a0Hernandez used sham companies set up in the British Virgin Islands and Panama\u00a0to conceal his ownership of\u00a0UBS accounts totaling $8.8 million.<\/p>\n April 15, 2010 \u2014 In Manhattan, N.Y., seven UBS clients were indicted for collectively hiding over $100 million in secret Swiss bank accounts. Two of these individuals, Jules Robbins and Federico Hernandez, pleaded guilty and agreed to pay civil penalties of $20.8 million and $4.4 million, respectively. The remaining indicted clients were Kenneth Heller, Sybil Nancy Upham, Richard Werdiger, Ernest Vogliano and Shmuel Sternfeld.<\/p><\/div>\n Oct. 5, 2009\u00a0\u2014 Roberto Cittadini<\/a>\u00a0of Bellevue, Wash.,\u00a0pleaded guilty to filing a false tax return and admitted to concealing nearly $2 million in Swiss bank accounts. Cittadini, a retired sales manager for Boeing, failed to file a Report Foreign Bank and Financial Accounts for 2001 through 2003. Cittadini was sentenced on Jan. 8, 2010, to six months home detention and one year supervised release and was ordered to pay a $10,000 fee and $17,985 in restitution.<\/p>\n Sept. 25, 2009\u00a0\u2014 Juergen Homann<\/a>\u00a0of Saddle River, N. J.,\u00a0pleaded guilty to failure to file a Report of Foreign Bank or Financial Accounts and accepted responsibility for concealing more than $5 million in Swiss bank accounts. Homann was sentenced on Jan. 6, 2010, to five years probation and was\u00a0ordered to pay a $60,000 fine.<\/p>\n Aug. 14, 2009\u00a0\u2014 John McCarthy<\/a>\u00a0of Malibu, Calif., pleaded guilty to failing to inform the government of a Swiss bank account as part of a scheme to move at least $1 million from the United States into Swiss bank accounts with the goal of avoiding the payment of federal income taxes. McCarthy was sentenced on March 22, 2010, to three years of supervised release with six months served in home detention and 300 hours community service.\u00a0In addition, he was ordered to pay a $25,000 fine and to file tax returns for 2003 through 2008 and pay all taxes due and owing.<\/p>\n July 28, 2009\u00a0\u2014 Jeffrey P. Chernick<\/a> of Stanfordville, N.Y., pleaded guilty\u00a0to charges of filing a false tax return. Chernick, who owns a corporation which represents toy manufacturers in China and Hong Kong,\u00a0accepted responsibility for concealing more than $8 million in Swiss bank accounts. Chernick was sentenced on Oct. 30, 2009, to three months in prison and one year of supervised release with six months served in home detention.<\/p>\n June 25, 2009\u00a0\u2014\u00a0UBS client Steven Michael Rubinstein<\/a>\u00a0of Boca Raton, Fla., pleaded guilty to filing a false tax return for tax year 2004. On April 1, 2009, Rubinstein was charged with filing a false tax return that intentionally failed to disclose the existence of a Swiss bank account maintained by UBS of which he was the beneficial owner and failed to report any income earned on that account. Rubinstein was sentenced on Oct.\u00a028, 2009, to three years probation, of which\u00a012 months will be served in home detention.<\/p>\n April 14, 2009\u00a0\u2014 Robert Moran<\/a> of Lighthouse Point, Fla., pleaded guilty\u00a0to a criminal information charging him with filing a false income tax return. Moran accepted responsibility for concealing more than $3 million in assets in a secret bank account at UBS in Switzerland. Moran was sentenced on Nov. 6, 2009, to two months in prison and one year of supervised release with five months in home confinement.<\/p>\n Nov. 18, 2011\u00a0\u2014\u00a0Renzo Gadola, a citizen and resident of Switzerland, was sentenced to five years probation.\u00a0Gadola pleaded guilty in December 2010 to assisting an American client in concealing an offshore bank account from the United States government. From 1995 through August 2008, he was employed as a private banker by UBS AG.<\/p>\n Aug. 4, 2011\u00a0\u2014 Gian Gisler<\/a>, a former UBS AG banker, was charged with conspiring to hide more than $215 million offshore at various Swiss banks.\u00a0Gisler had more than 38 U.S. taxpayer clients and allegedly opened and\/or managed more than 60 hidden accounts on their behalf.<\/p>\n July 21, 2011\u00a0\u2014 Beda Singenberger<\/a>, a Swiss financial advisor, was indicted for conspiring with U.S. taxpayers and others to hide more than $184 million in offshore Swiss bank accounts.<\/p>\n Aug. 21, 2009\u00a0\u2014\u00a0Former UBS banker Bradley Birkenfeld<\/a>\u00a0was sentenced to 40 months in prison. Birkenfeld worked as a private banker for UBS AG and assisted an American billionaire real estate developer evade paying $7.2 million in taxes.<\/p>\n Aug. 20, 2009\u00a0\u2014 Hansruedi Schumacher and Matthias Rickenbach\u00a0were indicted for conspiring to assist wealthy American clients conceal their assets by establishing sham\u00a0offshore entities. Schumacher was an executive manager at Neue Zuercher Bank (NZB), a private Swiss bank. Rickenbach was a Swiss attorney who advised U.S. clients.<\/p>\n Aug. 19, 2009\u00a0\u2014\u00a0 The Justice Department and the IRS today announced that an agreement<\/a>\u00a0has been reached\u00a0with the Swiss government\u00a0regarding the John Doe summons filed against UBS on June 30, 2008.<\/p>\n Feb. 18, 2009\u00a0\u2014\u00a0UBS AG, Switzerland\u2019s largest bank,\u00a0entered into a deferred prosecution agreement on charges of conspiring to defraud the United States by impeding the Internal Revenue Service (IRS).<\/p>\nUBS Clients<\/h3>\n
Legal Actions to Date<\/h3>\n