Monday, March 30, 2015

Sovereign's US Custormers Need To Make a Voluntary Disclosure NOW!

We originally posted Court Authorizes IRS to Issue Summonses For Records of U.S. Taxpayers Who Used Sovereign Management & Legal Ltd. to Conceal Offshore Accounts, Assets or Entities  which discussed that on December 19, 2014 the DoJ announced that U.S. District Judge Vernon S. Broderick entered an order on December 18, 2014 authorizing the IRS to issue summonses requiring:
  1. Federal Express Corporation, doing business as FedEx Express, 
  2. FedEx Ground Package System Inc., aka FedEx Ground, 
  3. DHL Express (DHL), 
  4. United Parcel Service Inc. (UPS), 
  5. Western Union Financial Services Inc., 
  6. the Federal Reserve Bank of New York (the FRBNY), 
  7. Clearing House Payments Company LLC, and 
  8. HSBC Bank USA National Association (HSBC USA) 
to produce information about U.S. taxpayers who may be evading or have evaded federal taxes by using the services of Sovereign Management & Legal Ltd. (Sovereign) to establish, maintain or conceal foreign accounts, assets and entities.

The John Doe summonses will now result in the abovementioned 8 entities producing records that will assist the IRS in identifying U.S. taxpayers who, used Sovereign’s services to establish, maintain, operate or control any foreign financial account or other assets; any foreign corporation, company, trust, foundation or other legal entity; or any foreign or domestic financial account in the name of such foreign entity.

  • As a result of a DEA investigation of online narcotics trafficking, the IRS learned that Sovereign was involved in assisting U.S. clients evade their taxes. 
  • In a voluntary disclosure made by a US taxpayer of tax non-compliance, the US taxpayer reported that Sovereign helped form an anonymous corporation in Panama that the US taxpayer used to control assets without appearing to own them.
  • The subsequent IRS investigation determined that Sovereign uses Federal Express, UPS and DHL to correspond with U.S. clients, and Western Union to transmit funds to and from clients in the United States.  In addition, the IRS learned that the wire services operated by the FRBNY and Clearing House, and the U.S. correspondent bank accounts that HSBC USA holds for Sovereign’s banks in Panama and Hong Kong, are likely to have records of financial transactions between Sovereign and its clients in the United States. 

By obtaining information from these entities 
through John Doe summonses, the IRS expects 
to be able to identify Sovereign’s U.S. Clients
 who may be avoiding or evading taxes.

Now that the IRS has issued these John Doe summonses to produce records that will assist the IRS in identifying U.S. taxpayers who, from 2005 through 2013, used Sovereign’s services; these US US taxpayers will most likely:
  1. be Audited by the IRS
  2. be subject to a combined 325% Tax & Penalty on the highest balance in their Sovereign foreign bank account
  3. be Criminally Prosecuted
  4. and do Jail Time!
 Have Un-Reported Income From a Sovereign 
Offshore Bank Account?

Protect Yourself from 325% Fines and Possible Jail Time. 

Contact Our Experienced Tax Attorneys to Find out
if the OVDP Program is Right for You?

Contact the Tax Lawyers at
Marini & Associates, P.A.
for a FREE Tax Consultation Contact US at
or Toll Free at 888-8TaxAid (888 882-9243)

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