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ARTICLE · 17 APRIL 2014

IRS Issues John Doe Summons For Hidden Accounts

A&O Shearman
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The US Government’s recent crackdown on offshore tax evasion shows no sign of slowing down and appears to be expanding to include new jurisdictions.

United StatesTax

The US Government's recent crackdown on offshore tax evasion shows no sign of slowing down and appears to be expanding to include new jurisdictions. On November 12, 2013, US District Judge Richard Berman of the Southern District of New York issued an order authorizing the IRS to issue "John Doe" summonses requiring the Bank of New York (Mellon), Citibank, JPMorgan Chase Bank NA, HSBC Bank USA NA and Bank of America to produce information about US taxpayers with undisclosed accounts at The Bank of N.T. Butterfield & Son Limited and its affiliates in the Bahamas, Barbados, Cayman Islands, Guernsey, Hong Kong, Malta, Switzerland and the United Kingdom. Previously, on November 7, 2013, US District Court Judge Kimba Wood of the Southern District of New York entered an order authorizing the IRS to issue John Doe summonses to the Bank of New York (Mellon) and Citibank to produce information about US taxpayers who may be evading federal taxes by holding interests in undisclosed

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