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JOHN DOE SUMMONS ISSUED IN EFFORT TO OBTAIN INFORMATION ON NON-COMPLIANT TAXPAYERS

     On April 30, 2013, the Justice Department announced that a federal court in San Francisco entered an order authorizing the Internal Revenue Service to serve a “John Doe summons” seeking information concerning U.S. taxpayers who may hold offshore accounts at FirstCaribbean International Bank (“FCIB”).  This type of summons is used by the IRS to obtain information about the possible violation of internal revenue laws by individuals whose identities are unknown.

    The summons seeks records of FCIB’s U.S. correspondent account at Wells Fargo, N.A., which will allow the IRS to identify U.S. taxpayers who hold an interest in a financial account at FCIB and other financial institutions that used FCIB’s Wells Fargo correspondent account.

     FCIB, based in Barbados and having branches in 18 different Caribbean nations, allegedly assisted certain U.S. taxpayers in keeping their offshore accounts undetected by the IRS, resulting in the nonpayment of federal income tax by such taxpayers with respect to their FCIB accounts.

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