CIBC (First Caribbean International Bank Account) Summoned: The Department of Justice is Seeking the Identities of U.S. Taxpayers with Undisclosed Offshore Accounts

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Kevin E. Thorn, Managing Partner of the Thorn Law Group comments on the Department of Justice's release on April 30, 2013, which announced on that a federal court in San Francisco authorized an order for the Internal Revenue Service (IRS) and the Department of Justice to serve a John Doe summons.

CIBC (First Caribbean International Bank Account) Summoned by IRS

A federal court in San Francisco authorized an order for the Internal Revenue Service (IRS) to serve a John Doe summons, which will allow the IRS to obtain records of U.S. taxpayers who hold or held undisclosed offshore accounts at the Canadian Imperial Bank of Commerce FirstCaribbean International Bank (FCIB); this includes the correspondent account at Wells Fargo that was used by FCIB.

John Doe Summonses are used by the IRS to obtain information on U.S. taxpayers, who may have undisclosed foreign accounts around the world and might be in violation of internal revenue laws. Federal tax laws require that U.S. taxpayer’s pay taxes on all income earned worldwide. Through the summons, the IRS hopes to obtain the identities of U.S. persons with accounts offshore, as well as information about the accounts and their contents.

“The Department of Justice and the IRS are committed to global enforcement to stop the use of foreign bank accounts to evade U.S. taxes, and this John Doe summons is a visible indication of how we are using the many tools available to us to pursue this activity wherever it is occurring. Those who are still hiding should get right with their country and their fellow taxpayers before it’s too late.” Said Kathryn Keneally, Assistant Attorney General for the Justice Department’s Tax Division, see Department of Justice release at

Kevin E. Thorn, who is the managing partner of Thorn Law Group, represents many U.S. taxpayers who have undisclosed offshore bank accounts around the world. Many of his clients are participating in the 2012 IRS Amnesty Program, and he states “U.S. taxpayers with undisclosed offshore accounts at FCIB face substantial risks by not coming forward at this time”. Risks include criminal prosecution and steep financial penalties.

He continues, “The Department of Justice and the Internal Revenue Service will continue to pressure all foreign banks to turnover U.S client information in order to bring U.S. taxpayers back into compliance.” According to Thorn, this latest attempt to obtain U.S. client account information from the Caribbean is not a surprise, as the IRS has made clear they will seek tax evasion by U.S. persons wherever it occurs and will pursue not only U.S. taxpayers, but the professionals who assisted them.

For additional information on this subject, contact Kevin E. Thorn, Managing Partner of Thorn
Law Group at 202-270-7273. Or visit us at

About Thorn Law Group, PLLC: Thorn Law Group is a law firm dedicated to helping clients resolve complicated tax, criminal tax, and international tax problems.

Kevin E. Thorn
Managing Partner
Thorn Law Group, PLLC

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