Tax

B.E. Capital Management Fund L.P. v. Fund.com Inc.: Special Master’s Report (‘Theft, Forgery & Tax Evasion’)

June 30, 2023

Special Master's Final Report and Recommendation, including a finding that Fund.com Inc. Receiver Thomas Braziel "committed conduct that, on its face, meets the elements of crimes that include theft, forgery, and tax evasion" in B.E. Capital Management Fund L.P. v. Fund.com Inc. at the Court of Chancery of the State of Delaware.

USA v. Stephen Schechter: Criminal Information (‘Offshore Tax Evasion’)

June 30, 2023

Criminal Information alleging tax evasion involving entities in the British Virgin Islands and bank accounts in Monaco and Switzerland in USA v. Stephen L. Schechter, described as a retired investment banker who is a dual citizen of the United Kingdom and USA residing in Monaco, at the U.S. District Court for the District of Columbia.

USA v. Mark Gyetvay: Complaint (‘$44M Tax Fraud’)

June 22, 2023

Complaint for $44 million alleging "willful FBAR penalties" involving companies or accounts in Belize, British Virgin Islands, Cayman Islands, Russia, and Switzerland in USA v. Mark Anthony Gyetvay, described as a citizen of Italy, Russia, and USA, at the U.S. District Court for the Middle District of Florida.

John Doe v. Germany: Motion to Proceed Under Pseudonym (‘Panama Papers Whistleblower’)

June 20, 2023

Plaintiff's Ex Parte Motion for Leave to Proceed Under A Pseudonym in John Doe v. The Federal Republic of Germany and The Bundeskriminalamt of the Federal Republic of Germany at the U.S. District Court for the District of Columbia.

John Doe v. Germany et al: Complaint (‘$14.5M Panama Papers Whistleblower Reward’)

June 20, 2023

Complaint alleging the German authorities owe $14.5 million to the 'Panama Papers whistleblower' in John Doe, unidentified but described as "a citizen of the United States" who was "the original source of the Panama Papers" v. The Federal Republic of Germany and The Bundeskriminalamt of the Federal Republic of Germany at the U.S. District Court for the District of Columbia.

USA v. Francis Burga et al: Second Amended Complaint (‘$120M Offshore Tax Avoidance Scheme’)

June 16, 2023

Second Amended Complaint for FBAR Penalties regarding accounts in the British Virgin Islands, Hong Kong, Liechtenstein, Panama, Singapore, Switzerland and other countries in USA v. Francis Burga, individually and as the Administrator of the Estate of Margelus Burga, at the U.S. District Court for the Northern District of California.

Bernard Tew et al v. ED&F Man Capital Markets Ltd.: Complaint (‘Tax Refund Fraud’)

June 14, 2023

Complaint alleging "a diabolical scheme orchestrated by Defendant ED&F to take advantage of the Plans' tax-exempt status in foreign countries by using the Plans to make fake securities trades, issue fake tax vouchers to a host of European governments, and steal hundreds of millions in tax refunds" in Bernard V. Tew, Stephanie Tew Campbell, Andrea B. Tew, and Vincent A. Tew, individually and as Trustees on behalf of Bluegrass Investment Management LLC Retirement Plan, Bluegrass Retirement Group Trust, MSJJ Retirement Group Trust, Autoparts Pensions Group Trust, Casting Pensions Group Trust, Central Technologies Pensions Group Trust, Industrial Pensions Group Trust, SV Holdings LLC Retirement Plan, Tew Enterprises LLC Retirement Plan, and Tew LP Retirement Plan v. ED&F Man Capital Markets Ltd., of London, England, at the U.S. Bankruptcy Court for the Eastern District of Kentucky.

Tax Analysts v. Internal Revenue Service: Complaint (‘U.S.-Mexico Income Tax Convention’)

June 12, 2023

Complaint under the Freedom of Information Act in Tax Analysts regarding "a taxpayer attempting to use the provisions of the U.S. - Mexico Income Tax Convention to excuse themself of their obligation to file Form 5471" v. Internal Revenue Service at the U.S. District Court for the District of Columbia.

USA v. John Chen et al: Criminal Indictment (‘Chinese Agent/IRS Bribery’)

June 9, 2023

Criminal Indictment alleging a conspiracy to bribe an IRS official on behalf of the Chinese Government to "topple" the Falun Gong religious movement in USA v. John Chen, a.k.a. Chen Jun, and Lin Feng at the U.S. District Court for the Southern District of New York.

USA v. Elaine Wolfe: Complaint (‘Failure to Report Swiss & UK Accounts’)

June 8, 2023

Complaint for damages of $559,475 for alleged "willful failure" to report financial interests in foreign bank accounts in USA v. Elaine V. Wolfe, described as a 95-year-old resident of Great Neck, New York who was "born in Salford, Lancashire, United Kingdom in 1928" and "moved to the United States in 1957", at the U.S. District Court for the Eastern District of New York.

USA v. John Chen et al: Criminal Complaint (‘Chinese Agent/IRS Bribery’)

May 24, 2023

Criminal Complaint alleging conspiracy to act as a foreign government agent for China, money laundering, and bribery of "a purported Internal Revenue Service agent who was in fact an undercover officer ... as part of a PRC Government-directed scheme to revoke the tax-exempt status of a 501(c)(3) organization run by Falun Gong practitioners" in USA v. John Chen, a.k.a. Chen Jun, and Lin Feng at the U.S. District Court for the Southern District of New York.

USA v. Nellie Makarova Cross: Complaint (‘$88K FBAR Penalties’)

May 24, 2023

Complaint alleging failure to disclose foreign accounts at banks in Russia and France in USA v. Nellie Makarova Cross at the U.S. District Court for the District of Rhode Island.

Mohamad Hachem et al v. Refinitiv US Organization LLC et al: Defamation Complaint (‘World-Check Database’)

May 4, 2023

Complaint "to recover damages caused by REFINITIV’s defamatory statements regarding Mr. Hachem’s criminal history after REFINITIV’s database falsely claimed that Mr. Hachem had been convicted of a federal financial felony and sentenced to one year in prison" in Mohamad Hachem and Sneaker Impact Inc. v. Refinitiv US Organization LLC and Refinitiv US LLC at the U.S. District Court for the Southern District of Florida.

Transportadora de Energia SA v. Internal Revenue Service: Discovery Application (Argentina)

May 4, 2023

Request for Judicial Assistance from the National Tax Court in Buenos Aires, Argentina "for the purpose of obtaining bank records from Banco Santander International" for use in a civil legal proceeding styled as 'Transportadora de Energia S.A. v. Internal Revenue Service', filed at the U.S. District Court for the Southern District of Florida.

Sam Allardyce et al v. Fat Cat Films Ltd.: Liquidation Application (‘£51.8M Debt’)

April 28, 2023

Originating Application in Michael Ward, Christopher Carpmael, Philip Stephen Bradley, Mike Hilton, Timothy Attias, Edward Bowen, Andrew Crane, Ray Davis, Mark Dormer, Kimbell Duncan, Tim Gledhill, John Goodridge, Bruce Hanton, Adam Hart, Mark Hobbs, Matthew Holland, Jeremy Isaacs, Glenn Jones, Tracey Jones, Tiina Lee, Jon Macintosh, Jason Mackay, Simon Meadows, Derek Mills, Eric Nicoli, John Nixon, Christopher Anthony Roads, Casper Shand-Kydd, Declan Walsh, Sam Allardyce, Kenan Altunis, Bryan Beeston, Graeme Blakey, EAM Boscawen, Andrew Boulton, John Brooksbank, Michael Coatman, Rick Corne, Peter Cowgill, The Earl of Derby, Elke Edwards, Robert Tregellas Elliott, Eric Entwistle, Gary Entwistle, Lorne Entwistle, Andrew Nicholas Gaskell, Martin Gavin, Michel Glas, Julie Green-Jones, Peter Horsman, Roger Humber, Nick Kelsey, Stephen Lister, Ross McDonald, Marc Middleton, Kevin Ohle, Raymond O'Leary, Charles Patchett, Michael Patchett, Peter Reid, David Renshaw, Russell Mark Roberts, Philip Robert-Tissot, Gordon Stephenson, David Stoller, Lee Stoller, Bernhard Weninger, John Ambery, Julian Beressi, Warren Briggs, Mark Cherry, Mike Cutler, Christopher Dale, Scott Harrison, Steve Jennings, Stephen Kingston, Richard Lewis, J.R. Lister, Fabrizio Pagani, Geoffrey Reid, Simon Ashworth, Ben Britz, Anthony Burling, Gavin Davidson-Merritt, Evan Huw Davies, Stephen Down, Nigel Higgins, Andrew Hill, Jacqueline E.S. Hoyland, John Nicolas Jeremy Hoyland, Byron Hurst, Ross K. Hyett, Brian Jones, Dr. Sonil Kalia, Daniel Kerven, Surrinder Kumar, Robert Leitao, Robert Meakin, Michael Moss, Timothy Francis Xavier Parr, Charles Pelham, Mark R. Perowne, Douglas Rae, Peter Sharpe, John Shepherd, Thomas Peter Tidy, and John Willis v. Fat Cat Films Limited at the British Virgin Islands High Court.

USA v. Kraken: Kraken’s Opposition to IRS Petition (‘Crypto Tax Evasion’)

April 21, 2023

Payward Ventures Inc.'s opposition to Petition to Enforce IRS Summons in USA v. Payward Ventures Inc., d.b.a. Kraken, a crypto exchange, at the U.S. District Court for the Northern District of California.

OffshoreAlert Miami – Final Agenda

April 18, 2023

After some late tweaks, the agenda for next week's OffshoreAlert Miami conference is now final - and it's one of the best that we've ever put on.

OffshoreAlert Miami: Walking the Walk

April 14, 2023

During 26 years of exposing investment frauds, tax scams, and money laundering schemes, OffshoreAlert has developed unparalleled experience and expertise in the areas of intelligence, investigations, and recovery in high-value international finance. We've earned our spurs in this business the hardest way possible.

USA v. Francis Burga: First Amended Complaint (‘$120M Offshore Tax Avoidance Scheme’)

April 12, 2023

First Amended Complaint for FBAR Penalties regarding accounts in the British Virgin Islands, Liechtenstein, Panama, Singapore, Switzerland and other countries in USA v. Francis Burga, individually and as the Administrator of the Estate of Margelus Burga, at the U.S. District Court for the Northern District of California.

Accused U.S. tax fraudsters Stein & Lhote sue Danish Tax Authority for ‘breaching settlement agreement’

April 12, 2023

American "finance professionals" Matthew Stein and Jerome Lhote have filed a complaint in New York against the Danish Tax Authority for allegedly breaching an agreement to settle a DKK 1.1 billion tax refund fraud investigation in a manner that they claim contributed to them being criminally charged two years later.

Matthew Stein et al v. Skatteforvaltningen: Complaint (‘Danish Tax Fraud Settlement’)

April 6, 2023

Complaint "for breach of a settlement agreement between Plaintiffs, two finance professionals, and Defendant, the taxation authority of the Kingdom of Denmark" in Matthew Stein and Jerome Lhote v. Skatteforvaltningen at the U.S. District Court for the Southern District of New York.

State of New York v. Donald Trump: Criminal Indictment & Statement of Facts (‘Stormy Daniels Fraud’)

April 4, 2023

Criminal Indictment alleging the defendant "repeatedly and fraudulently falsified New York business records to conceal criminal conduct that hid damaging information from the voting public during the 2016 presidential election" in The People of the State of New York v. Donald J. Trump, a former president of the United States, at the Supreme Court of the State of New York, County of New York.

USA v. Dennis Brite: Criminal Indictment (‘Offshore Tax Evasion’)

March 8, 2023

Criminal Indictment for alleged tax evasion involving offshore entities in Belize, Nevis, Saint Vincent and the Grenadines, and the Seychelles in USA v. Dennis Wayne Brite at the U.S. District Court for the District of South Carolina.

Jeepers Creepers 3 LLC v. Brandon Farm LLC: Petition to Vacate $1.1M Arbitration Award (‘Movie Tax Credits’)

March 1, 2023

Petition to Vacate Arbitration Award regarding tax credits in Jeepers Creepers 3 LLC, of Louisiana, managed by Jake Seal, a British film producer v. Brandon Farm LLC, of Delaware, whose principal was identified as Michael Ohoven, a German film producer, at the U.S. District Court for the Central District of California.

USA v. Babak Golbahar: Complaint (‘Unreported Offshore Accounts’)

March 1, 2023

Complaint for $1.7 million in allegedly unpaid penalties for failure to report two offshore accounts to the IRS in USA v. Babak Golbahar at the U.S. District Court for the Central District of California.

USA v. Kraken: Petition to Enforce IRS Summons (‘Crypto Tax Evasion’)

February 3, 2023

Petition to Enforce IRS Summons regarding "an investigation to determine the identity and correct federal income tax liability of U.S. persons who conducted transactions in cryptocurrency for the years ended December 31, 2016, 2017, 2018, 2019, and 2020" in USA v. Payward Ventures Inc., d.b.a. Kraken, described as a crypto exchange, at the U.S. District Court for the Northern District of California.

USA v. $310,276 Seized From Accounts at Bank of Saipan: Forfeiture Complaint (‘Fraud & Money Laundering’)

December 30, 2022

Forfeiture Complaint regarding funds associated with "a suspected conspiracy by foreign entities and entities and individuals in the Commonwealth of the Northern Mariana Islands to commit wire fraud and money laundering" involving entities, inter alia, in Bermuda and the British Virgin Islands in USA v. $271,088 and $39,188 seized from accounts at the Bank of Saipan in the name of a company referred to as "MCS", filed at the U.S. District Court for the Northern Mariana Islands.

Video: IRS Presentation: Taxing Crypto

December 9, 2022

ETS MIR LLC v. Petroci Holding Côte d’Ivoire: Complaint (‘Irregular Tax Situation’)

December 2, 2022

Complaint alleging "unilateral, wrongful and unlawful purported termination of two agreements between the parties, based upon a pretext of unsupported claims of 'irregular tax situation'" in ETS MIR LLC v. Petroci Holding Côte d'Ivoire, a.k.a. National Oil Company of Côte d'Ivoire, of the Ivory Coast, at the U.S. District Court for the Southern District of New York.

Samuel Malamud Eidelman v. Truist Bank et al: Discovery Application (Peru)

November 29, 2022

Application by Samuel Malamud Eidelman, described as a citizen of Peru, to take discovery from Truist Bank, Credit Lyonnais Miami Agency, Bank Leumi, BNP Paribas Miami Agency, Barclays, Sudameris, Banco Santander International, Grupo Santander, and Blum & Silver LLP for use in legal proceedings in Peru against Jacobo Malamud and his three daughters, Malamud Kessler, Caroline Malamud-Kessler, and Yudith Malamud Kessler de Schneider alleging money laundering and tax evasion involving, inter alia, companies in the British Virgin Islands, filed at the U.S. District Court for the Southern District of Florida.

Louise Blouin et al v. USA: Complaint (‘Trust Fund Taxes’)

November 28, 2022

Complaint "to strike off certain Federal Tax Liens that were purportedly or attempted to be filed against property owned by Aberdeen Enterprises, Inc., a Delaware Corporation, as a result of an attempt by the Internal Revenue Service to collect on behalf of the United States certain Trust Fund Recovery Penalties, 26 U.S.C. § 6672 purportedly imposed against Louise Blouin" in Aberdeen Enterprises Inc., described as a Delaware company owned by a British Virgin Islands company, and Louise Blouin, a citizen of Canada residing in Switzerland v. USA at the U.S. District Court for the Eastern District of New York.

USA v. Carlos Kepke: Death Notification (‘Offshore Tax Fraud’)

November 28, 2022

Minutes noting the death of the defendant, Carlos Kepke, an attorney who had been indicted for alleged tax fraud conspiracy involving accounts or companies in Belize, British Virgin Islands, Cayman Islands, Nevis, and Switzerland, in USA v. Carlos E. Kepke at the U. S. District Court for the Northern District of California.

USA v. Carlos Kepke: USA’s Trial Memorandum (‘Offshore Tax Fraud’)

November 15, 2022

USA's Trial Memorandum regarding an alleged offshore tax fraud scheme involving accounts or entities in Belize, British Virgin Islands, Cayman Islands, Nevis, and Switzerland that allowed businessman Robert Smith "to evade federal income taxes on approximately $225,000,000 of capital gains" in USA v. Carlos Kepke, an attorney, at the U.S. District Court for the Northern District of California.

Anadarko China Holdings 2 Company et al v. Win Business Energy (Caofeidian) Ltd.: Liquidation Application

November 11, 2022

Originating Application in Anadarko China Holdings 2 Company and Anadarko Petroleum Corporation v. Win Business Energy (Caofeidian) Limited at the British Virgin Islands High Court.

Brazil: Paulo Retz et al (‘Tax Evasion’)

November 4, 2022

Application for the appointment of a Commissioner to collect evidence from Delta Bank - pursuant to a request for judicial assistance from Brazil - for a criminal investigation into "Paulo Roberto Retz and Grethen Financial Inc. for tax evasion".

USA v. Nancy Metzler et al: Amended Complaint (‘Undisclosed Swiss & UK Accounts’)

November 2, 2022

Amended Complaint to collect penalties totaling $590,000 from the Estate of Narinder Singh, who "willfully failed to disclose" five accounts at at Union Bancaire Privée in Switzerland and one at Barclays Bank PLC in the United Kingdom whose "highest aggregate balance" in 2011 was "more than $7.2 million" in USA v. Nancy Metzler and Shalu Arjomand, each in their capacity as Executor for the Estate of Narinder Singh, at the U.S. District Court for the Southern District of New York.

USA v. Frank Butselaar: Criminal Indictment (‘Offshore Tax Evasion’)

October 20, 2022

Criminal Indictment accusing the defendant of "designing and implementing a fraudulent tax evasion scheme ... to conceal millions of dollars of worldwide income earned by certain high net worth clients", including two "internationally renowned" electronic dance music disc jockeys and "certain fashion industry clients", in USA v. Frank Butselaar, described as a citizen of the Netherlands who "referred to himself as a 'tax lawyer'" even though "he was not an attorney in any jurisdiction", at the U.S. District Court for the Southern District of New York.

USA v. Narinder Singh: Complaint (‘Unreported Offshore Accounts’)

September 29, 2022

Complaint to collect unpaid penalties of $590,000 that were imposed for "willful violations" of the Bank Secrecy Act by failing to disclose accounts at Union Bancaire Privée in Switzerland and Barclays Bank Plc in the United Kingdom in USA v. Narinder Singh at the U.S. District Court for the Southern District of New York.

USA v. Joseph Cammarata: Criminal Indictment (New Jersey)

September 22, 2022

Criminal Indictment alleging tax evasion involving entities in the Bahamas, Colombia, Gibraltar, and USA in USA v. Joseph Cammarata at the U.S. District Court for the District of New Jersey.

New York AG v. Donald Trump et al: Complaint (‘$250M Accounting Fraud’)

September 21, 2022

Complaint alleging "numerous acts of fraud and misrepresentation in the preparation of Mr. Trump’s annual statements of financial condition" that "grossly inflated Mr. Trump’s personal net worth as reported in the Statements by billions of dollars" in People of the State of New York v. Donald J. Trump, Donald Trump Jr., Eric Trump, Ivanka Trump, Allen Weisselberg, Jeffrey McConney, The Donald J. Trump Organization Inc., Trump Organization LLC, DJT Holdings LLC, DJT Holdings Managing Member, Trump Endeavor 12 LLC, 401 North Wabash Venture LLC, Trump Old Post Office LLC, 40 Wall Street LLC, and Seven Springs LLC at the Supreme Court of the State of New York, County of New York.

Gol Linhas Aéreas Inteligentes SA: $70M Penalty

September 15, 2022

Administrative Order by the U.S. Securities and Exchange Commission that it has imposed disgorgement and interest totaling $70 million on GOL Linhas Aéreas Inteligentes SA, a.k.a. GOL Intelligent Airlines Inc., of São Paulo, described as "the second largest domestic airline in Brazil by market share", for "a scheme to bribe government officials in Brazil in exchange for certain payroll tax and fuel tax reductions that financially benefited Gol, along with other airlines".

Sayantani Ghose v. Ernst and Young LLP: Complaint (‘Whistleblower Retaliation’)

September 14, 2022

Complaint alleging whistleblower retaliation in Sayantani Ghose, described as someone who "contributed enormously to Ernst & Young, LLP for 15 years, moved up the ranks to partner and became an internationally known expert in transfer pricing, only to have her career at EY end because she refused to sign off on transactions that she believed violated tax and securities laws" v. Ernst & Young LLP, described as a Delaware "audit firm" based in New York, at the U.S. District Court for the Southern District of New York.

Piero Dyer Coriat v. IRS et al: Petition to Quash IRS Summons

August 31, 2022

Petition to Quash IRS Summons in Piero Martin Dyer Coriat, described as a citizen and resident of Peru v. Internal Revenue Service and Truist Bank at the U.S. District Court for the Southern District of Florida.

USA v. sFOX Inc.: Order Granting ‘John Doe’ Summons (‘Crypto Tax Liabilities Investigation’)

August 15, 2022

Order Granting Ex Parte Petition for Leave to Serve ‘John Doe’ Summons for an investigation into the tax liabilities of cryptocurrency clients in USA v. OX Labs Inc., d.b.a. sFOX Inc., at the U.S. District Court for the Central District of California.

IRS investigates tax liabilities of crypto clients of Safra Bank & trading platform sFOX

August 8, 2022

The USA has applied to serve IRS 'John Doe' summonses on M.Y. Safra Bank and "cryptocurrency prime dealer and trading platform" OX Labs, d.b.a. sFOX, at federal courts in New York and California as part of an investigation into the tax liabilities of their cryptocurrency clients.

USA v. M.Y. Safra Bank: Petition to Serve IRS ‘John Doe’ Summons (‘Crypto Tax Liabilities Investigation’)

August 8, 2022

Ex Parte Petition for Leave to Serve 'John Doe' Summons for an investigation into the tax liabilities of cryptocurrency clients in USA v. M.Y. Safra Bank at the U.S. District Court for the Southern District of New York.

USA v. sFOX Inc.: Petition to Serve IRS ‘John Doe’ Summons (‘Crypto Tax Liabilities Investigation’)

August 8, 2022

Ex Parte Petition for Leave to Serve 'John Doe' Summons for an investigation into the tax liabilities of cryptocurrency clients in USA v. OX Labs Inc., d.b.a. sFOX Inc., at the U.S. District Court for the Central District of California.

USA v. Zachary Friedman: Criminal Information (‘Tax Evasion’)

August 1, 2022

Criminal Information alleging tax evasion in USA v. Zachary Friedman, described as "a United States citizen whose permanent residence was in New York, New York, or Dubai, United Arab Emirates", at the U.S. District Court for the District of Columbia.

Lithuania: BMO Harris Bank (‘Tax Evasion Investigation’)

August 1, 2022

Application for the appointment of a Commissioner to collect evidence from BMO Harris Bank - pursuant to a request for judicial assistance from Lithuania - for a criminal investigation into an unidentified company for fraud, appropriation of property, incorrect reporting of income, profits, and assets; fraudulent accounting, and forgery of documents.

‘I know where you live,’ writes IRS target Kevin Wessell

August 1, 2022

Letter from self-described "asset protection expert" Kevin Wessell letting OffshoreAlert's publisher know that he has his full name and home address and requesting the removal "within 48 hours" of the word 'fraud' to describe an IRS investigation into his "Wessell Group" or face hearing from "my attorneys".