According to DoJ, a Florida woman, and dual U.S. and
Colombian citizen, pleaded guilty on March 10, 2025 to conspiring to defraud the United
States by, among other things, concealing tens of millions of dollars in
undeclared foreign financial accounts, filing false tax returns, and evading
taxes.
According to court documents and
statements made in court, between 2010 and 2022, Gilda Rosenberg, of Golden
Beach, Florida, conspired with two family members to conceal from the IRS more
than $90 million in assets and income held in undeclared bank accounts in
Andorra, Israel, Panama and Switzerland.
Rosenberg’s family had maintained
offshore accounts since the 1970s. By the late 1990s, Rosenberg, who was
identified as an owner and an authorized signer on some of the accounts, knew
that she and her family members had not disclosed their ownership of these
foreign financial accounts to the U.S. government and that they had not paid
any taxes on the income earned from the assets in those accounts as was
required by law.
Starting in the early 2000s, the
family consolidated their assets at accounts with Credit Suisse in Switzerland
and the United Kingdom. Family members told Credit Suisse employees that they
were U.S. persons and seeking to hide their assets from U.S. authorities. The
assets remained at Credit Suisse until 2013, when Credit Suisse closed the
accounts because the family members were U.S. persons.
When Credit Suisse closed their
accounts, the family moved their assets, which were typically titled in the
names of nominee entities, to new accounts located at Bank Leumi in
Israel, Union Bancaire Privée (UBP) and PKB Privat Bank SA in Switzerland, and
an Andorran bank.
Rosenberg Was Documented As The Beneficial Owner Of Accounts At UBP And The Andorran Bank. She Also Signed
False Account Opening Documents That Claimed She Was
A Colombian Resident And Not A U.S. Citizen.
Rosenberg, as well as her
relatives, did not file Reports of Foreign Bank and Financial Accounts (FBARS)
disclosing their foreign financial accounts, as they were required to do. In
addition, Rosenberg and her relatives continued to file false tax returns that
omitted income generated by their offshore assets.
In or about 2017, as part of a
scheme to continue to evade their U.S. tax and reporting obligations, Rosenberg
and the family members divided the family’s assets and signed documents to make
it appear that Rosenberg and a relative gifted the offshore assets to another
relative after he had renounced his U.S. citizenship.
Rosenberg and her
relatives then tried to covertly transfer assets to Rosenberg in the United
States and to conceal their ongoing and historical tax evasion. To do so,
Rosenberg and her relatives, among other things, created fake loan and
investment documents to make it appear that transfers to and from Rosenberg
were loans and business investments.
From 2010 Through 2017, Rosenberg Filed False Tax
Returns That Did Not Report More Than $5.5 Million In
Income She Earned From Her Assets At UBP, Which
Caused A Tax Loss To The IRS Of $1,927,342.
Rosenberg is scheduled to be
sentenced on May 30. She faces a maximum penalty of five years in prison as
well as a period of supervised release, restitution and monetary penalties. A
federal district court judge will determine any sentence after considering the
U.S. Sentencing Guidelines and other statutory factors.
Do You Have Undeclared Offshore Income?
Want to Know 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
