The United States tax authorities have filed a request for legal assistance to identify former American clients of the private bank Wegelin who are suspected of tax dodging. It is the fourth such request against a Swiss financial institute.
Wegelin, which announced at the beginning of this year it would close its doors, on Friday confirmed reports that it had received notification by Switzerland’s Federal Tax Authorities to comply with the US request, based on a 1996 double taxation agreement.
A bank official added that Wegelin would submit the necessary information.
The request focuses on former Wegelin clients who were listed as beneficiaries of asset management companies between 2002 and 2012 and are suspected of fiscal fraud, according to the Neue Zürcher Zeitung newspaper on Friday.
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It is the fourth such demand against Swiss banks. The country’s two main banks, UBS and Credit Suisse, have also faced requests against a particular group of clients over the past few years.JAT Comments:
1. Note that the request "focuses" on those clients "listed as beneficiaries of asset management companies between 2002 and 2012 and are suspected of fiscal fraud."The report does not indicate what either of these conjunctive descriptions are.
2. By contrast, the Julius Baer request I previously reported, see U.S. Treaty Request for Julius Baer Domiciliary Company Accounts with U.S. Beneficiaries (Federal Tax Crimes Blog 5/28/13), here, asked for information on "domiciliary company accounts." I think I understand at least to some extent what that "domiciliary company accounts" means -- i.e., the U.S. taxpayer inserted one or more entities between him and the account to obscure ownership. But, apparently, that was not the request made to Wegelin, at least as described in the report.
3. It seems to me that "asset management companies" could mean either the companies (or entities, however described) which the client owned through which the client beneficially owned the bank account(s) or it might mean the Swiss asset management companies who managed bank accounts for U.S. taxpayers. I would appreciate a reader or readers either commenting or emailing me with an understanding of what information is being requested.