Further, Ms. Novack reports::
Already, judges have approved previously unreported summonses for records from PNC Bank and RBS Citizens in the Western District of Pennsylvania; USAA Federal Savings Bank in the Western District of Texas; BOKF and 66 Federal Credit Union in the Northern District of Oklahoma; Prairie Sun Bank in Minnesota; and East West Bank and Global Cash Card in the Central District of California. Summons requests involving Wells Fargo WFC -0.32% and JP Morgan Chase, among others, are pending. There is no suggestion in the DOJ’s court filings that any of the U.S. institutions have done anything improper.Each of the summonses
asks for information about bank account applications, signature cards and other records tied to one or a few specific payment or credit card numbers that have been used over a period of years for ATM withdrawals and other transactions in Norway which require a PIN, but don’t require the card holder’s name. For example, according to a court-filed affidavit from IRS agent Cheryl Kiger, Norway reports one East West Bank payment card it wants information about was used from 2004 through 2012 for 661 transactions in Norway totaling 1,305,400 Norwegian Krone (NOK). (That’s $221,918 at an average exchange rate for the period of one Krone equaling 17 U.S. cents.)I will post more as I receive it, but obviously if the U.S. insists on such John Doe treaty requests when it makes them, it will have to reciprocate when treaty partners make them. In this regard, historically exchange of information treaty requests have required some identification of the taxpayer. However, as observers of the U.S.-Swiss spat know, Switzerland has recently approved "group requests" -- I call them John Doe treaty requests. See Swiss Court Ruling in Credit Suisse Case (Federal Tax Crimes Blog 7/8/13), here.
Readers should also read the comments to Ms. Novack's posting. One of the commenters is "justme" is known on this blog as Just Me or Just Me Also. His comments are always good.
Addendum 7/19/13 3:22 pm:
See the DOJ Tax Announcement: Federal Courts Authorize Service of John Doe Summonses Seeking Identities of Persons Using Payment Cards in Norway (7/29/13), here. Excerpts:
The lawsuits are a part of ongoing international efforts to stop persons from using foreign financial accounts as a way to evade taxes. Courts have previously approved John Doe summonses allowing the IRS to identify individuals using offshore accounts to evade their U. S tax obligations. In the present suits, the Justice Department is seeking the identities of persons who may be attempting to hide their Norwegian taxable income in U.S. financial accounts.
Below is a list of the decided and pending cases. Copies of the pleadings will be made available on the Tax Division’s website :
In the Matter of the Tax Liabilities of John Does , Case No. 13-cv-01097 (C.D. Calif.)
In the Matter of the Tax Liabilities of John Doe , Case No. 13-mc-00056 (D. Minn.)
In the Matter of the Tax Liabilities of John Does , Case No. 13-mc-00024 (E.D. Va.)
In the Matter of the Tax Liabilities of John Does , Case No. 13-mc-00018 (N.D. Okla.)
In the Matter of the Tax Liabilities of John Does , Case No. 13-cv-01066 (W.D. Pa.)
In the Matter of the Tax Liabilities of John Doe , Case No. 13-mc-00657 (W.D. Tex.)
In the Matter of the Tax Liabilities of John Doe , Case No. 13-mc-00232 (W.D. Tex.)
In the Matter of the Tax Liabilities of John Does , Case No. 13-cv-03393 (N.D. Calif.)
In the Matter of the Tax Liabilities of John Doe , Case No. 13-mc-00301 (S.D. Miss.)
In the Matter of the Tax Liabilities of John Doe , Case No. 13-mc-00038 (D. N.H.)