米国国税が在米インド人の課税逃れを調査 HSBCに名簿提出命令
HSBC drawn into US tax pursuit
By Suzanne Kapner in New York
Published: April 8 2011 00:54 | Last updated: April 8 2011 00:54
The US Department of Justice has asked a federal judge to force HSBC to reveal the names of thousands of the bank's wealthy clients who are suspected of tax evasion in the US.
The request is the strongest sign yet that US authorities have broadened their scrutiny of potential tax dodgers beyond the traditional havens of Switzerland and a few small Caribbean countries. A judge's approval is required before the Internal Revenue Service can issue a summons.
US officials are focusing on thousands of US-based high-net worth clients who held accounts with both HSBC USA and an affiliate in India from 2002 until 2010. HSBC had told US officials that there were 9,000 such accounts, which require a minimum balance of $100,000, as of September 2010, according to court papers. And yet for all of 2009, the most recent year for which data are available, paperwork filed with the IRS disclosed only 1,921 accounts, the court documents show.
"This indicates that thousands of United States taxpayers of Indian origin who maintain more than $100,000 in accounts with HSBC may have failed to disclose their HSBC India accounts to the United States government," says a written statement submitted to the court by Daniel Reeves, the IRS's senior adviser on offshore compliance. "It is also likely that those taxpayers may have failed to report income earned on those undisclosed accounts."
HSBC said that it had not yet seen the court filings, adding that it did not condone tax evasion and fully supported the US government in its effort to collect appropriate taxes. "We have been engaged in a constructive dialogue with US authorities and hope any ‘IRS summons' issues can be resolved expeditiously," the bank said.
HSBC is the latest multi-national bank to find itself in the cross hairs of US tax authorities. After the US government filed similar requests for information about UBS clients in 2008, the Swiss government agreed to turn over 4,450 names. The bank paid $780m to settle criminal charges that it had helped Americans use offshore accounts to evade taxes.
Some HSBC clients had been alerted that they were the subject of a criminal tax evasion probe last July, when they received a letter from the justice department. HSBC had first surfaced as a possible target for tax authorities early last year in two separate cases, one against a surgeon who had pleaded guilty to illegally squirrelling away $250,000 in offshore accounts and another against father-and-son hotel developers accused of hiding $150m in assets. Both cases involved a large bank reported to be HSBC.
By Suzanne Kapner in New York
Published: April 8 2011 00:54 | Last updated: April 8 2011 00:54
The US Department of Justice has asked a federal judge to force HSBC to reveal the names of thousands of the bank's wealthy clients who are suspected of tax evasion in the US.
The request is the strongest sign yet that US authorities have broadened their scrutiny of potential tax dodgers beyond the traditional havens of Switzerland and a few small Caribbean countries. A judge's approval is required before the Internal Revenue Service can issue a summons.
US officials are focusing on thousands of US-based high-net worth clients who held accounts with both HSBC USA and an affiliate in India from 2002 until 2010. HSBC had told US officials that there were 9,000 such accounts, which require a minimum balance of $100,000, as of September 2010, according to court papers. And yet for all of 2009, the most recent year for which data are available, paperwork filed with the IRS disclosed only 1,921 accounts, the court documents show.
"This indicates that thousands of United States taxpayers of Indian origin who maintain more than $100,000 in accounts with HSBC may have failed to disclose their HSBC India accounts to the United States government," says a written statement submitted to the court by Daniel Reeves, the IRS's senior adviser on offshore compliance. "It is also likely that those taxpayers may have failed to report income earned on those undisclosed accounts."
HSBC said that it had not yet seen the court filings, adding that it did not condone tax evasion and fully supported the US government in its effort to collect appropriate taxes. "We have been engaged in a constructive dialogue with US authorities and hope any ‘IRS summons' issues can be resolved expeditiously," the bank said.
HSBC is the latest multi-national bank to find itself in the cross hairs of US tax authorities. After the US government filed similar requests for information about UBS clients in 2008, the Swiss government agreed to turn over 4,450 names. The bank paid $780m to settle criminal charges that it had helped Americans use offshore accounts to evade taxes.
Some HSBC clients had been alerted that they were the subject of a criminal tax evasion probe last July, when they received a letter from the justice department. HSBC had first surfaced as a possible target for tax authorities early last year in two separate cases, one against a surgeon who had pleaded guilty to illegally squirrelling away $250,000 in offshore accounts and another against father-and-son hotel developers accused of hiding $150m in assets. Both cases involved a large bank reported to be HSBC.
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