Voluntary Disclosures Lead to John Doe Summonses for Information about U.S. Accounts at Zurcher Kantonalbank and Bank of Butterfield

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In a sign that the U.S. government continues to aggressively seek information on U.S. taxpayers with non-U.S. bank accounts, the government announced on November 12, 2013, that it had obtained a court order authorizing the government to issue so-called “John Doe summonses” for information on U.S. account holders at Zurcher Kantonalbank in Switzerland and Bank of N.T. Butterfield & Son Ltd. in the Bahamas, Barbados, the Cayman Islands, Guernsey, Hong Kong, Malta, Switzerland, and the United Kingdom. The U.S. government will use the John Doe summonses to force the U.S. banks that hold correspondent bank accounts for the non-U.S. banks to turn over records on the transactions that the U.S. banks conducted on behalf of U.S. customers of the non-U.S. banks. The U.S. banks who will receive the John Doe summonses are Bank of New York Mellon, Citibank NA, JPMorgan Chase Bank NA, HSBC Bank USA NA, and Bank of America NA. The government appears to have been motivated to seek the John Doe summonses by information that the IRS received from U.S. taxpayers who entered the Offshore Voluntary Disclosure Program. The government announced that to date, U.S. taxpayers have identified 371 previously undisclosed accounts at ZKB and 81 such accounts at Butterfield.