White-Collar Crime

Lawyer is Federally Charged re Claimed Conspiracy to Use Swiss Bank Accounts to Defraud IRS

A lawyer has been criminally charged concerning a series of events beginning with a meeting more than a decade ago at a New York hotel. There, authorities say, members of an American family described as “the Seggermans” were advised about how to bring millions into the United States from an offshore bank account or accounts totaling $10 million without paying required estate and income tax.

In a criminal complaint announced Friday by the U.S. Attorney in Manhattan, lawyer Michael Little is accused of participating in a conspiracy to use Swiss bank accounts and sham mortgage transactions to help his clients, the Seggermans, defraud the Internal Revenue Service, according to Bloomberg and a press release (PDF) from U.S. Attorney Preet Bharara.

Little, 61, lives principally in Hampshire, England, and was arrested and charged with one count of conspiracy Thursday evening as he flew into John F. Kennedy International Airport, near another home he maintains in Long Island City, N.Y., the press release says. He appeared before a federal magistrate on Friday, but it isn’t clear whether he has been released.

The complaint (PDF), which was provided to the ABA Journal by the U.S. Attorney’s office, says Little is a British lawyer who is licensed in New York. A New Jersey accountant and a Swiss attorney are among the unindicted claimed co-conspirators.

The complaint alleges that Little advised members of the client family to “establish Swiss bank accounts and attendant entities, which would be nominally owned and/or controlled” by Little and the Swiss lawyer. The Swiss lawyer opened a UBS AG account for the benefit of one family member, the complaint continues. It also alleges that Little “enlisted” the accountant to prepare and family members to sign false U.S. tax returns.

The Bloomberg article does not include any comment from Little or his counsel, and the ABA Journal was unable to locate a working phone number for him in New York. An email sent to a company for which he apparently serves as a director did not receive an immediate response.

As detailed in earlier ABAJournal.com posts, the IRS has for years been pursuing civil and criminal enforcement matters concerning UBS AG and individual Americans who have had secret accounts at the Swiss bank.

Amnesty and reduced penalties have been offered to individuals who came forward about such accounts, and the complaint says one or more members of the client family in the case concerning Little have been cooperating.

Updated at 4 p.m. to include and accord with information from U.S. Attorney’s press release.

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