You've all read the UBS story concerning the battles that
the Swiss bank had with the US Department of Justice and, more
particularly, the US IRS regarding the default of US tax-payers
where they were hiding undeclared income, not disclosing same and,
therefore, not paying taxes in the US.
Since 2000 onwards the US IRS have been using the "John
Doe" summonses to identify US tax-payers hiding money off
shore without paying US tax. However, with the UBS debacle
their use has grown considerably.
The two main weapons used by the US Government in the UBS case
were the whistle-blower Bradley Birkenfeld who was a former UBS
banker in the United States and the use of "John Doe"
summonses. What "John Doe" summonses have done in
the United States is that the IRS have gone into the various
federal courts in the United States with certain information
concerning certain bank accounts of which they do not know who the
true owner is. The courts grant a very wide summons
