In a News Release, the Department of Justice (DOJ) announced that several U.S. district courts have authorized the IRS to serve John Doe summonses on various Trident Trust entities. The summoned entities are members of a multinational group of affiliated companies known as the "Trident Trust." Group."
The U.S. District Court for the Northern District of Georgia entered an order earlier this week authorizing the IRS to serve John Doe summonses on TT (USA) Holdings Inc.; Trident Corporate Services Inc. and Trident Fund Services Inc., entities that are members of a multinational group of affiliated companies generally operating under the trade name “Trident Trust” and collectively referred to as the “Trident Trust Group.”
Separately, on Dec. 18, 2024, the U.S. District Court for the District of South Dakota entered an order, unsealed on Jan. 21, authorizing service of a similar John Doe summons on Trident Trust Company (South Dakota) Inc. The United States also previously obtained approval in the U.S. District Court for the Southern District of New York for the IRS to serve John Doe summonses on a different affiliate entity of the Trident Trust Group, as well as to third party financial service companies, banks and courier services that may have information about Trident Trust Group’s U.S. taxpayer clients.
The United States is not alleging that any of the entities engaged in wrongdoing. Rather, the IRS uses John Doe summonses to obtain information about possible violations of internal revenue laws by individuals whose identities are unknown. These summonses seek information about U.S. individuals who may have used the Trident Trust Group’s services to underreport their worldwide income and conceal their ownership of certain foreign assets that U.S. individuals are required to report to the U.S. government.
A declaration from an IRS revenue agent that accompanied the petitions alleges that at least nine U.S. taxpayers used Trident Trust Group’s services to avoid compliance with U.S. tax laws. The declaration further alleges that the IRS learned of this noncompliance through the Offshore Voluntary Disclosure Program, a program that allowed U.S. taxpayers to voluntarily disclose foreign accounts or entities used to evade tax in exchange for settling their civil liabilities on fixed terms.
A representative of Trident Trust responded to us that:
“We are aware of the IRS petitions. Each of our trust and corporate services businesses is regulated in the jurisdiction in which it operates and is fully committed to compliance with all applicable regulations. All clients are assessed via a thorough onboarding process.
“Trident Trust proactively informs the relevant authorities where any compliance process gives rise to concerns. We also fulfil our obligations in relation to the Automatic Exchange of Information in taxation matters, including FATCA and CRS reporting.”
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