Foreign Bank Account Holders Beware

The Justice Department announced a few days ago that it had obtained a “John Doe Summons” to serve on Wells Fargo Bank requiring Wells Fargo to disclose all customers who may have transferred money to or through the Canadian Imperial Bank of Commerce First Caribbean International Bank (FCIB) through the FCIB’s correspondent account with Wells Fargo. A correspondent account is a bank deposit account maintained by one bank for another bank, in this case FCIB. The summons allows the IRS to identify individuals who have accounts with the FCIB. As reported by the Wall Street Journal, the IRS learned of Wells Fargo’s involvement through the voluntary disclosures of taxpayers taking advantage of the IRS’ voluntary disclosure program (1). Since 2009, the IRS has netted $5.5 billion in additional revenue through its voluntary disclosure program(2). With each disclosure, the IRS learns more about where people are hiding their assets and how they are getting them there. If you have offshore bank accounts or other foreign assets that have not been disclosed to the IRS, contact the trusted tax attorneys of the Dana Law Firm to discuss your options, before the IRS finds you.

Written by: Shad Brown, Attorney at Dana Law Firm


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