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 The 34-page ruling, which paraphrased an IRS request for judicial
aid and did not provide supporting documents, is the fullest public
picture so far of the case against Julius Baer, one of a dozen of
Swiss banks that are the subject of a criminal investigation in the
United States into tax evasion.
Julius Baer declined to comment on the ruling.
According to the Swiss ruling, U.S. tax authorities alleged at least
400 Americans hid more than $600 million from the IRS. Julius Baer
private bankers used "codenames and numbers", as well as "travelling
account statements", to conceal the identity of the account owners,
the court document stated.
The bank also advised wealthy Americans to use "sham corporate
entities" to hide their money and ensured that bank correspondence
wouldn't be sent to them in the United States in order to avoid
detection, the court said, citing the IRS judicial aid request.
Julius Baer told clients they were safe from IRS prying because the
Swiss bank didn't have a U.S. office, unlike larger rivals such as
UBS, according to the court documents.
Baer has in past said it is cooperating with U.S. authorities, is
eager to settle, and that it has handed over documents and other
material illustrating its business in the United States.
The Swiss court said the IRS pieced together the information from
the indictment in 2011 of two former Julius Baer private bankers,
Daniela Casadei and Fabio Frazzetto, as well as from voluntary
disclosures from more than 400 one-time clients of the Swiss bank
who admitted to their hidden accounts.
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Casadei and Frazzetto helped wealthy American clients of Julius Baer
hide roughly $600 million in assets in secret Swiss bank accounts
that went undeclared to the IRS, according to the 2011 indictment.
The details of the U.S. case against Baer came to light through a
ruling backing an appeal by two clients of the bank. The court ruled
the couple's bank account data must not be disclosed to U.S. tax
authorities, because the IRS had not provided enough detail to
warrant judicial assistance from Switzerland.
A host of Swiss banks not being targeted last month signaled their
readiness to work with U.S. officials in the crackdown on wealthy
Americans evading taxes. The number that join the scheme is key for
larger banks facing criminal investigations in the United States,
such as Credit Suisse, Baer and Pictet & Cie.
(Reporting by Alice Baghdjian and
Katharina Bart; editing by David Evans)
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