A U.S. judge authorized the Internal Revenue Service to seek information about possible tax evasion through offshore accounts at Canadian Imperial Bank of Commerce’s FirstCaribbean International Bank.
The IRS may seek information on FCIB’s U.S. customers by serving a so-called John Doe summons on Wells Fargo & Co., which holds the bank’s U.S. correspondent account, U.S. District Judge Thelton Henderson ruled yesterday in federal court in San Francisco.
At least 129 taxpayers voluntarily disclosed to the IRS that they held undeclared accounts at FCIB, based in Barbados, according to an affidavit by IRS Revenue Agent Cheryl Kiger. Several other people have been convicted of financial crimes involving accounts at FCIB, according to Kiger.
“The persons in the ‘John Doe’ class may have failed to report the existence of foreign financial accounts under their control, failed to report income, evaded income taxes, or otherwise violated the internal revenue laws of the United States,” according to the Kiger affidavit.
“We will review the summons and respond as legally required,” Ancel Martinez, a spokesman for San Francisco-based Wells Fargo, said in an e-mailed statement. Wells Fargo is the fourth-largest U.S. bank by assets.
Mary Lou Frazer, a spokeswoman for Toronto-based CIBC, didn’t immediately return a voice-mail message seeking comment.
The case is In the Matter of the Tax Liabilities of John Does, 13-cv-01938, U.S. District Court, Northern District of California (San Francisco).