Accessing Records With Bank of Nova Scotia Summonses

May 23, 2016  |  New York Law Journal

In a recent interview, Acting Assistant Attorney General Caroline D. Ciraolo described the Tax Division’s continuing pursuit of individuals believed to have evaded their U.S. tax obligations through offshore accounts. Among other things, Ms. Ciraolo noted that, in the wake of the DOJ’s Swiss Bank Program, the Tax Division’s civil trial attorneys were seeking to enforce Bank of Nova Scotia summonses served on U.S branches of foreign banks. This article discusses the authority supporting the use of such summonses to avoid foreign bank secrecy laws and the implications of so-called Bank of Nova Scotia summonses looking forward.

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