The major crack in Swiss bank secrecy opened in February 2009, when prosecutors charged UBS AG with conspiring to cheat the IRS. UBS, the largest Swiss bank, avoided prosecution by paying $780 million, admitting it fostered tax evasion and handing over data on thousands of clients.
Singenberger, who lives in Zurich, was charged in New York federal court in July 2011 with conspiracy to cheat the IRS.
Sinco Treuhand
He ran Zurich-based Sinco Treuhand AG, a wealth management and tax-advisory business. Like other offshore bankers charged by the Justice Department, Singenberger is accused of managing, opening and transferring accounts for his U.S. clients. He visited his clients in the U.S., delivering cash from their undeclared accounts or taking cash back to deposit in Switzerland, court records show.
One New York client who banked with UBS for a half-century once had a $74 million account, while a California client of UBS had a $47 million account, prosecutors said.
Most Swiss banks promised the IRS in 2001 that they would obtain documents on the real owners of accounts and would withhold taxes on some transactions. The Justice Department has charged advisers like Singenberger with defeating the purpose of that agreement by hiding the true identities of account owners.
Singenberger created sham foundations in Liechtenstein and phony corporations in Hong Kong and the British Virgin Islands to help clients hide their ownership of the accounts, prosecutors charged. The accounts had names like Lucky Overseas Ventures Ltd. and Ample Lion Ltd.
Two Sets
Prosecutors said Singenberger prepared one set of IRS forms for the banks that falsely said the foundations or corporations were the real owners and another set of forms required by Swiss law that truthfully said his clients were the actual owners.
After the UBS investigation became public in 2008, he helped clients move accounts to other Swiss banks to keep them under wraps, prosecutors said. Those banks included Wegelin & Co., the oldest Swiss private bank.