U.S. Account Holders at HSBC Now Under Scrutiny

Tax Notes Today reports that some U.S. owners of HSBC accounts are receiving letters from DOJ Tax Criminal Section advising that they are targets of criminal investigations with respect to their offshore accounts. Jeremiah Coder, HSBC Clients Under Criminal Investigation, 2010 TNT 128-1 (7/6/10); for past Blog discussions on HSBC see here.) Excerpts from short article are:

The Justice Department has opened criminal investigations into U.S. taxpayers with suspected unreported offshore accounts in HSBC Holdings PLC, practitioners told Tax Analysts July 2.

The practitioners, who spoke on the condition of anonymity, said the DOJ has sent letters to several taxpayers referencing HSBC as a potential target and notifying the account holders that they could be referred for criminal charges.

The DOJ does not appear to have identified the taxpayers using data received from Switzerland, because several of the contacted taxpayers hold offshore accounts only outside Europe, one practitioner said. Investigators may be using data from India to home in on HSBC accounts, another practitioner said.

Addenda

Additional reports are indicate:

1.  As to the connection with India, some reports (see here) speculate that the Indian Government may have provided the information under information exchange treaty provisions.  The article quotes an unnamed official as saying:  ""In all probability, Indian authorities must have passed on the information to their US counterparts through various exchange of information mechanisms either through bilateral or multilateral agreements,"


Additional Web Resources:

Bloomberg 
Main Justice
New York Times (Reuters)