U.S. District Court Grants Government’s Motion to Issue John Doe Summons to HSBC

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On April 7, 2011, the U.S. District Court for the Northern District of California, in case # 4:11-cv-1686, granted the Governments ex parte motion to issue “John Doe” summons to HSBC. The full text of the order can be found here

Of particular note is the description of the “John Does” “ “United States taxpayers, who at any time during the years ended December 31, 2002 through December 31, 2010, directly or indirectly had interests in or signature or other authority (including authority to withdraw funds; trade or give instructions to receive account statements, confirmations, or other information, advice or solicitations) with respect to any financial accounts maintained at, monitored by, or managed through the Hongkong and Shanghai Banking Corporation Limited in India (HSBC India)”.

As we previously discussed, those that have a financial interest and/or control over foreign accounts must disclose the accounts to the Department of the Treasury. The IRS recently announced a second offshore voluntary disclosure initiative to those that still had not come forward to be compliant with the reporting requirements. Our prior discussion regarding this second voluntary disclosure initiative can be found here.

The attorneys at Fuerst Ittleman, PL have extensive experience in voluntary disclosures, offshore accounts, IRS audits, and criminal tax investigations. You can reach an attorney by emailing us at: contact@fidjlaw.com.