WOMAN WILL PAY $21 MILLION PENALTY FOR NOT DISCLOSING SWISS BANK ACCOUNT INCOME

FROM: U.S. DEPARTMENT OF JUSTICE

Tuesday, January 8, 2013

South Florida Woman Pleads Guilty to Failing to Disclose Income from Swiss Bank Accounts and Agrees to $21 Million Penalty

Mary Estelle Curran of Palm Beach, Fla., pleaded guilty today in the U.S. District Court for the Southern District of Florida to filing false tax returns for tax years 2006 and 2007, the Justice Department and Internal Revenue Service, Criminal Investigation (IRS-CI) announced.

According to court documents, Curran, a U.S. citizen, maintained undeclared bank accounts at UBS AG in Switzerland and a bank in Liechtenstein, which she inherited from her husband in 2000. The accounts at UBS AG were held in the names of nominee foreign entities, including the Flognet Foundation and Norega Investment. The account earned income each year, which Curran failed to report on her 2001 through 2007 individual income tax returns.

According to the plea agreement, Curran’s conduct caused a tax loss to the government of approximately $667,716. The value of all undeclared foreign financial accounts owned or controlled by Curran exceeded $42 million in 2007. In order to resolve her civil liability for failure to report her foreign bank accounts, Curran has agreed to pay a civil penalty in the amount of 50 percent of the high balance of the accounts, which is $21,666,929.

"The Justice Department continues to pursue those who hide income and assets from the IRS through the use of nominee businesses and offshore bank accounts," said Assistant Attorney General Keneally. "U.S. taxpayers who fail to come forward in the voluntary disclosure program risk prosecution and substantial fines, as this case demonstrates."

"U.S. citizens who seek to avoid their tax obligations by hiding income in undeclared bank accounts abroad should by now be fully on notice that they will be held accountable for their actions, both civilly and criminally," said U.S. Attorney for the Southern District of Florida Wifredo A. Ferrer. "The U.S. Attorney’s Office is committed to helping the IRS enforce our nation’s tax laws."

"Offshore accounts can no longer be used to hide from the IRS and avoid paying the fair amount of tax," said Richard Weber, Chief, IRS Criminal Investigation. "IRS Criminal Investigation is aggressively pursuing tax cheats – both domestically and internationally. We owe it to every American taxpayer to use all lawful means to identify and prosecute both those who evade their taxes and those who assist them in evading their tax obligations."

Curran faces a potential maximum prison term of six years. A sentencing date has not been set.

Assistant Attorney General Keneally and U.S. Attorney Ferrer thanked Special Agents of IRS - CI, who investigated the case, and Tax Division Senior Litigation Counsel Mark F. Daly and Trial Attorney Michelle M. Petersen and Assistant U.S. Attorney Thomas P. Lanigan, who prosecuted the case.