International Law

Lawyer Held In Lieu of $2M Bail re Claimed Conspiracy to Help Clients Avoid Tax on Offshore $10M

A lawyer who has been federally indicted on accusations he participated in a conspiracy to help relatives of a retired Fidelity Investments executive avoid estate and income tax on $10 million in offshore funds was still in jail at last report, being held in lieu of $2 million bond.

A federal magistrate judge in New York said Michael Little, 61, must post $1 million in cash or property to win his release, according to the Guardian and the Wall Street Journal.

Attorney Elkan Abramowitz represents Little. He told the WSJ in an email: “We are studying the charges contained in the complaint. We are confident that in the end we will be able to demonstrate that there is no merit to them.”

Little is admitted both in New York and the United Kingdom, where he primarily resides with his wife and children. He was arrested Thursday when he arrived at John F. Kennedy International Airport in New York on a flight from London. He is accused of advising and aiding five relatives of the late Harry Seggerman to avoid tax by bringing money from Swiss accounts into the U.S. in small amounts and under false pretenses. Seggerman retired from Fidelity as a vice chairman in 1992 and died in 2001.

Little is accused of helping his clients transfer money from a Swiss account into London, generally in amounts of less than $10,000, ostensibly to purchase art or jewelry, from where they could take the money home to the U.S. He is also accused of creating a sham mortgage that allegedly gave a family member access to $600,000.

An earlier post provides a link to the criminal complaint (PDF) in the case.

It says Seggerman family members used code words to discuss the offshore assets. “Small” allegedly referred to Little, “FDA” meant the Internal Revenue Service and “beef” meant money.

If convicted, Little could get a maximum five-year prison term.

Additional coverage:

Associated Press: “British attorney accused of keeping cash for family of ex-Fidelity Investments exec overseas”

The Lawyer: “Kings Bench barrister held in US over alleged $10m tax fraud”

The Local: “Swiss lawyer wanted in US family fraud case”

New York Times (reg. req.): “Family Told How to Hide Inheritance, U.S. Claims”

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