IRS Seeks Names of U.S. Account Holders at HSBC (India)

Just a few short weeks ago, we described in these pages (Indictment of Offshore Account Holder Portends – a New Round of Aggressive Enforcement [2011] 4 ILT 163) a recent grand jury indictment of a U.S. taxpayer who held an unreported account at HSBC (India), and predicted that the criminal charges in U.S. v. Dahake heralded a new wave of U.S. tax enforcement against taxpayers of Indian descent with accounts at that bank.