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Tax Notes Talks to Arielle Borsos on Recent John Doe Summonses

May 2, 2019, Tax Notes

A federal court has authorized the IRS to serve John Doe summonses on three U.S. financial institutions in an effort to identify Finnish residents who may be hiding income in U.S. bank accounts.

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The United States has previously used John Doe summonses to get information on individuals from the Netherlands and Norway. Arielle Borsos of Caplin & Drysdale noted that by seeking information for Finland, the United States “is building strong precedent for the use of such summonses on behalf of its treaty partners in the future.”

Practitioners also noted that a side benefit of the John Doe summons could be to improve the United States' reputation. In addition to “other recent initiatives, such as requiring foreign-owned U.S. disregarded entities to file Forms 5472 and implementing the [Financial Crimes Enforcement Network] customer due diligence requirements for financial institutions,” Borsos said that seeking information from Finland helps the United States counter the "tax haven" label. She noted that it shows that the United States is committed to “global transparency and combating offshore tax evasion worldwide.”

For the full article, please visit Tax Notes’ website (subscription required).

Excerpt taken from the article “John Doe Summonses Authorized for Finnish Residents' Bank Info" by Annagabriella Colón for Tax Notes.

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