The summons demands all records of Sovereign Management & Legal's clients (SML). The phrase 'John Doe' indicates that the US authorities do not know the clients' identities, but the summons applies to them irrespectively of that fact.
According to the US Department of Justice (DoJ), the company issued clients with prepaid debit cards called 'Sovereign Gold Cards' that enabled them to access the funds in the offshore accounts 'in such a manner as to evade their obligations under internal revenue laws'.
The accounts were opened by SML in the names of corporations that were owned by other entities such as fake charitable foundations, and held in the name of nominee officers provided by SML.
US District Court Judge Brian Morris found that there is a reasonable basis for believing that US taxpayers may be using Sovereign Gold Cards to violate federal tax laws.
Taxpayers that have issues related to these transactions should immediately seek the guidance of a tax advisor with significant experience in US international tax issues and voluntary disclosure practices.
The utilization of the OVDP or the Streamlined Filing Compliance Procedures is the first line of defense against substantial civil penalties and criminal prosecution.
Want to Know if the OVDP Program is Right for You?
Read more at: Tax Times blog