U.S. Department of Justice charges former UBS banker Christos Bagios with conspiracy to defraud the United States
The United States Attorney’s Office for the Southern District of Florida together with the Department of Justice – Tax Division, charged via information Christos Bagios, now a senior banker at Credit Suisse, of conspiring to defraud the United States of income taxes from U.S. citizens and residents pursuant to 18 U.S.C. section 371, commonly referred to as a Klein Conspiracy. Section 371 is available in full here.
According to the criminal complaint, Bagios, while he worked at UBS from 1999 through 2005, helped U.S. taxpayers hide assets from the U.S. government. U.S. taxpayers have an obligation under the Bank Secrecy Act to report foreign bank accounts to the U.S. Treasury. The Bank Secrecy Act is enforced by the Department of the Treasury – Financial Crimes Enforcement Network; see http://www.fincen.gov/statutes_regs/bsa/
According to the information, Bagios aided as many 150 U.S. clients in a bid to conceal between $400 million and $500 million from the Internal Revenue Service. The IRS has been delegated the authority to administer the Foreign Bank Account Report (“FBAR”) forms (Form TD 90.22-1) available here.
As we have previously blogged, four other Swiss bankers were charged last week with helping Americans evade U.S. taxes.
The full text of the criminal complaint can be found here
As we noted before, it appears that in the wake of the UBS deferred prosecution and the indictment, trial and conviction of Maurico Cohen Assor and his son, the Department of Justice is stepping up and continuing enforcement of tax related crimes. The attorneys at Fuerst Ittleman have extensive experience in criminal and civil tax litigation and regularly represent those being investigated for criminal tax offenses. If you have questions regarding income tax and reporting obligations, contact Fuerst Ittleman at firstname.lastname@example.org.