Court Authorizes John Doe Summons on U.S. Owner of Panamanian Firm

On January 25, 2017, a U.S. District Court in Montana unsealed an order authorizing the Internal Revenue Service (IRS) to serve a John Doe summons on Michael Behr of Bozeman, Montana, seeking information about U.S. taxpayers who may hold offshore accounts established by Sovereign Management & Legal LTD (SML), a Panamanian entity.  In particular, the IRS seeks records of U.S. taxpayers who, during the years 2005 to 2016, obtained a “Sovereign Gold Card” debit card that could be used to access the funds in those accounts in a way as to evade their obligations under U.S. tax laws.  The IRS employs John Doe summons to obtain information about possible violations of U.S. tax laws by individuals whose identities are unknown.