U.S. Court Authorizes John Doe Summonses about Finnish Residents Using 3 U.S. Bank Payment Cards Linked to Non-Finnish Bank Accounts

By Bruce Zagaris On May 1, 2019, the U.S. Department of Justice announced that a U.S. Court in North Carolina authorized the Internal Revenue Service to serve John Doe summonses on Bank of America, Charles Schwab, and TD Bank in an order that was unsealed on April 30.  The John Doe summonses seek information about persons residing in Finland that have Bank of America, Charles Schwab, or TD Bank payment cards linked to bank accounts located outside of Finland.  The summonses are known as “John Doe” summonses because the IRS does not know the identity of the persons under investigation. The U.S. petitioned the U.S. District Court for the Western District of North Carolina to authorize the summons at the request of the Finnish government under the tax treaty between Finland and the U.S.  The treaty permits the two countries to cooperate in exchanging information that is required to carry out each country’s tax laws.  The IRS summons requests…

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