As alleged in the Indictment unsealed today in Manhattan federal court:
DOYLE, assisted by others – including Beda Singenberger, a Swiss citizen who ran a financial advisory firm – established and maintained undeclared bank accounts in Switzerland to hide those accounts from the IRS. DOYLE used a sham entity to conceal from the IRS her ownership of some of the undeclared accounts and deliberately failed to report the accounts and the income generated in the accounts to the IRS.
In 2003, DOYLE’s father died and secretly left an inheritance of over $4 million to DOYLE. DOYLE, who was appointed the executor of her father’s estate, made court filings falsely stating under penalty of perjury that the total value of her father’s estate was under $1 million when, in truth and fact, it was more than four times that amount.
Thereafter, in 2006, DOYLE, with Singenberger’s assistance, opened an undeclared Swiss bank account for the purpose of depositing the secret inheritance from her father. The account was opened in the name of a sham foundation formed under the laws of Lichtenstein to conceal DOYLE’s ownership. As of December 31, 2008, the account held assets valued at approximately $3,548,380.
In 2010, the sham foundation controlled by DOYLE was re-domiciled from Lichtenstein to Panama. As of May 31, 2010, the sham foundation maintained assets of at least approximately $3,151,961.37.
For each of the calendar years from 2004 through 2009, DOYLE willfully failed to report on her tax returns her interest in the undeclared accounts and the income generated in those accounts. For each of these years, Doyle also failed to file a Report of Foreign Bank and Financial Accounts (FBAR) with the IRS, as the law required her to do.
Singenberger was charged on July 21, 2011, with conspiring with U.S. taxpayers and others to defraud the United States, evade U.S. income taxes, and file false U.S. tax returns. He remains at large.JAT Comments:
1. Beda Singenberger who has appeared several times in blog entries, here. He was a Swiss enabler through a financial advisory firm. The indictment alleges (par. 29): "Between in or about 2007 and in or about 2010, Singenberger provided to one of his U.S. taxpayer clients a document (the "Singenberger Client List") containing significant details regarding clients and prospective clients who were U.S. taxpayers (including LACY DOYLE, the defendant) [List of details omitted]. (Par. 29.) For a previous blog discussing the list , see: U.S. Using a Client List of Indicted Swiss Banker/Enabler (3/14/13), here. Presumably since Singenberger is still at large, the DOJ's access to the list came from the U.S. taxpayer.
2. As with virtually all of the prosecutions, entities were involved and great lengths taken to hide the assets.
3. Note that the allegations are that Doyle failed to report the account interest on income tax return and failed to file FBARs for the years 2004 through 2009. (See also indictment pars. 43 ff.) It is not clear what happened in the later years. The indictment says (par. 15) that Doyle continued obstructive activities "through in or about 2012."
4. The banks involved are Credit Suisse and 4 other foreign banks pseudonymed serially (Indictment pars. 10-14): Foreign Bank A (UK bank with headquarters in London), Foreign Bank B (Swiss Bank with headquarters in Basel), Foreign Bank C (Luxembourg bank, with headquarters in Strassen), and Foreign Bank D (Swiss Bank with headquarters in Zurich).