Tax Analysts Tax Notes is reporting that HENRY SEGGERMAN pled guilty today in Manhattan federal court to charges related to his participation in a scheme with family members to hide in secret Swiss bank accounts, and not reveal to the Internal Revenue Service ("IRS"), over $12 million that had been left to SEGGERMAN and his family members by SEGGERMAN's father. SEGGERMAN pled guilty before U.S. Magistrate Judge James C. Francis IV.

According to the Information, statements made during the plea proceedings, and other documents filed in Manhattan federal court:

SEGGERMAN was the son of a prominent New York businessman ("the Businessman") who, upon passing away in May 2001, left an estate valued in excess of $24 million, more than half of which was maintained in secret and undeclared foreign bank accounts. Working with a Swiss lawyer and others, the Businessman arranged for over $12 million in the undeclared accounts to be left to his surviving spouse and five of his children, including SEGGERMAN. As a result of the successful implementation of that plan, and to hide the undeclared funds from the IRS, SEGGERMAN, who, together with three of his siblings, was an executor of his father's estate, signed a tax return for his father's estate that falsely under-reported the gross assets of the Businessman's estate. In particular, the estate tax return fraudulently failed to report over $5 million left to the Businessman's wife and over $7.5 million to be split among five of his children.

In addition, the Swiss lawyer thereafter assisted SEGGERMAN's siblings, including Suzanne Seggerman, Yvonne Seggerman, and Edmund Seggerman, in setting up undeclared Swiss bank accounts to hold the money left to them by their father. SEGGERMAN assisted his brother in surreptitiously transferring funds from the brother's Swiss account to a bank account for a foundation controlled by SEGGERMAN, who thereafter filtered the funds to the brother in the United States, labeling the transfer as "loans."

SEGGERMAN, 60, of New York, New York, and Los Angeles, California, pled guilty to one count of conspiracy to defraud the United States, one count of subscribing to a false and fraudulent estate tax return, and one count of aiding and assisting in the preparation of false tax returns for his brother. He faces a total maximum sentence of 11 years in prison. The case is assigned to U.S. District Judge Alvin K. Hellerstein, and no sentencing date has been set. In addition, SEGGERMAN agreed as part of his guilty plea to make a payment of approximately $600,000 at the time of his sentencing, in partial satisfaction of the ultimate restitution obligation he faces at sentencing.

Suzanne Seggerman, Yvonne Seggerman, and Edmund Seggerman each previously pled guilty to one count of conspiracy to defraud the United States, and two counts of subscribing to false and fraudulent tax returns. Each faces a maximum sentence of 11 years in prison. Suzanne Seggerman, 51, of New York, New York, pled guilty before U.S. District Judge Kevin Thomas Duffy on October 14, 2010 and awaits sentencing. Yvonne Seggerman, 58, of Cumberland, Rhode Island, pled guilty before U.S. District Judge Paul A. Engelmayer on March 14, 2013 and awaits sentencing. Edmund Seggerman, 50, of Washington, D.C., pled guilty before U.S. District Judge Thomas P. Griesa on March 21, 2013 and awaits sentencing.