U.S. Judges Authorize IRS to Issue John Doe Summons for Records of U.S. Taxpayer Accounts at Zurcher Kantonalbank and Bank of N.T. Butterfield & Son. Limited and Affiliates

On November 7 and 12, 2013, two U.S. District Court judges issued orders authorizing the IRS to issue summons to banks to produce information about U.S. taxpayers who may be evading or have evaded federal taxes by holding interests in undisclosed accounts.  U.S. District Judge Kimba M. Wood of the Southern District of New York entered an order authorizing the IRS to issue summonses requiring Bank of New York Mellon (Mellon) and Citibank NA (Citibank) to produce such information  with respect  to accounts at Zurcher Kantonalbank and its affiliates (collectively, ZKB) in Switzerland.  On November 12, 2013, U.S. District Judge Richard M. Berman of the Southern District of New York entered an order, authorizing the IRS to issue summons requiring Mellon, Citibank, JPMorgan Chase Bank N.A. (JPMorgan), HSBC Bank USA NA (HSBC), and Bank of America NA (Bank of America) to produce similar information in connection with undisclosed accounts at the Bank of N.T. Butterfield & Son Limited and its affiliates (collectively, Butterfield) in the Bahamas, Barbados, Cayman Islands, Guernsey, Hong Kong, Malta, Switzerland, and the United Kingdom.