Federal Court in San Francisco Authorizes Service of John Doe Summons on Wells Fargo Seeking the Identities of U.S. Taxpayers with Offshore Accounts

A federal court in San Francisco authorized the Internal Revenue Service (IRS) to serve a John Doe Summons seeking information about U.S. taxpayers who hold correspondent accounts at Wells Fargo for Canadian Imperial Bank of Commerce's FirstCaribbean International Bank (FCIB) and may be using such accounts to evade U.S. tax.

A John Doe summons is any summons where the name of the taxpayer under investigation is unknown and therefore not specifically identified. A John Doe summons can only be served after federal court approval.

FCIB is the latest of several offshore banks served with similar information demands as part of the IRS's continuing effort to identify U.S. taxpayers who have assets and income hidden offshore. Swiss banking giant UBS, Wegelin and HSBC are among banks previously targeted by the IRS.

"The Department of Justice and the IRS are committed to global enforcement to stop the use of foreign bank accounts to evade U.S. taxes," said Kathryn Keneally, Assistant Attorney General for the Justice Department's Tax Division. "This John Doe summons is a visible indication of how we are using the many tools available to us to pursue this activity wherever it is occurring. Those who are still hiding should get right with their country and their fellow taxpayers before it is too late."

In this case, the IRS may serve the John Doe summons on Wells Fargo Bank., which holds FCIB's U.S. correspondent account. At least 129 taxpayers voluntarily disclosed to the IRS that they held undeclared accounts at FCIB, according to an affidavit by IRS Revenue Agent Cheryl Kiger. According to Kiger, several other people have been convicted of financial crimes involving accounts at FCIB.

To read the U.S. Justice Department announcement, click here.

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