HSBC: DOJ Goes After Taxpayers with Undisclosed Offshore Accounts in India

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The Department of Justice has recently announced an investigation into HSBC Bank through the issuance of a "John Doe" Summons. Kevin E. Thorn, a tax controversy attorney with experience as a former Internal Revenue Service attorney, comments on the unfolding investigation.

The possibility of a ‘John Doe’ Summons should encourage more U.S. taxpayers with undisclosed offshore accounts held at HSBC to come forward.

On April 7, 2011, the Honorable Phyllis J. Hamilton of the United States District Court for the District of Northern California ordered the Internal Revenue Service to serve a "John Doe" Summons on HSBC Bank USA, NA for HSBC's records relating to United States taxpayers with interests in financial accounts in India. This follows the announcement by the Department of Justice(DOJ) that the government has expanded its investigation of U.S. taxpayers with foreign bank accounts to include undisclosed foreign bank accounts with HSBC. Specifically, the government has reason to believe that many unnamed taxpayers have been investing with HSBC India through HSBC USA in order to evade taxes.

The recent order by the court allows the Internal Revenue Service (IRS) to issue a "John Doe" Summons against HSBC. The Summons is an attempt to force HSBC USA to provide the government with bank records identifying U.S. taxpayers that have opened and/or invested with a foreign HSBC branch. Currently, the government has ongoing investigations into certain undisclosed foreign accounts at HSBC, which they suspect are owned by U.S. taxpayers. The government hopes these investigations will provide information regarding the identity of these U.S. persons.

Kevin E. Thorn, Managing Partner of Thorn Law Group, a law firm that represents many taxpayers throughout the U.S. and around the world with undisclosed offshore accounts, believes "that the possibility of a 'John Doe' Summons should encourage more U.S. taxpayers with undisclosed offshore accounts held at HSBC to come forward. With the current IRS Amnesty Program only open until August 31, 2011, there is still enough time for taxpayers to enter the IRS Voluntary Disclosure Program and submit all necessary documents in order to be given amnesty from criminal prosecution." Adds Thorn, "It is critical for taxpayers to come forward before the bank identifies them to the IRS if they want to minimize their penalties and avoid criminal investigation."

Mr. Thorn encourages, "all U.S. taxpayers to contact a tax controversy attorney immediately in order to assess and minimize their exposure throughout these ongoing investigations. The 2011 Offshore Voluntary Disclosure Initiative may very likely be the last of its kind."

For additional information on the news that is the subject of this release, contact Kevin E. Thorn, Managing Partner of Thorn Law Group at 202-270-7273 or visit us at
http://www.newjersey-tax-lawyer.com.

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

Contact:
Kevin E. Thorn, Managing Partner
Thorn Law Group, PLLC
202-270-7273
http://www.newjersey-tax-lawyer.com

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