Manhattan Art Consultant Charged In Federal Court For Failing To Disclose Millions In Swiss Bank Accounts And Income

Allegedly Used Sham Trusts in Panama and Liechtenstein to Hide Assets

Preet Bharara, the United States Attorney for the Southern District of New York, and Shantelle P. Kitchen, Special Agent in Charge of the New York Field Office of the Internal Revenue Service, Criminal Investigation (“IRS-CI”), announced today the unsealing of an indictment against LACY DOYLE for obstructing the administration of the internal revenue laws and subscribing to a false tax return in connection with DOYLE’s establishment and maintenance of at least six secret, undeclared bank accounts in Switzerland and France.  DOYLE was arrested in lower Manhattan this morning and appeared before U.S. Magistrate Judge Ronald L. Ellis earlier today. 

U.S. Attorney Preet Bharara said: “As alleged in the indictment, Lacy Doyle went to extraordinary lengths to hide millions of dollars in assets and income from the IRS in overseas bank accounts.  As today’s charges make clear, my Office, and our partners at the IRS, will follow our investigations of U.S. tax law violations wherever they lead.”

IRS-CI Special Agent in Charge Shantelle P. Kitchen said: “The use of offshore bank accounts to conceal income and assets remains a very high priority for the Internal Revenue Service.  IRS-Criminal Investigation has made great progress in getting access to offshore account information.  We will continue to utilize the resources at our disposal to uncover U.S. taxpayers who willfully evade taxes by hiding their money out of the country.”

As alleged in the Indictment unsealed today in Manhattan federal court:[1]

DOYLE, assisted by others – including Beda Singenberger, a Swiss citizen who ran a financial advisory firm – established and maintained undeclared bank accounts in Switzerland to hide those accounts from the IRS.  DOYLE used a sham entity to conceal from the IRS her ownership of some of the undeclared accounts and deliberately failed to report the accounts and the income generated in the accounts to the IRS.

In 2003, DOYLE’s father died and secretly left an inheritance of over $4 million to DOYLE.  DOYLE, who was appointed the executor of her father’s estate, made court filings falsely stating under penalty of perjury that the total value of her father’s estate was under $1 million when, in truth and fact, it was more than four times that amount.

Thereafter, in 2006, DOYLE, with Singenberger’s assistance, opened an undeclared Swiss bank account for the purpose of depositing the secret inheritance from her father.  The account was opened in the name of a sham foundation formed under the laws of Lichtenstein to conceal DOYLE’s ownership.  As of December 31, 2008, the account held assets valued at approximately $3,548,380.

In 2010, the sham foundation controlled by DOYLE was re-domiciled from Lichtenstein to Panama.  As of May 31, 2010, the sham foundation maintained assets of at least approximately $3,151,961.37.

For each of the calendar years from 2004 through 2009, DOYLE willfully failed to report on her tax returns her interest in the undeclared accounts and the income generated in those accounts.  For each of these years, Doyle also failed to file a Report of Foreign Bank and Financial Accounts (FBAR) with the IRS, as the law required her to do.

Singenberger was charged on July 21, 2011, with conspiring with U.S. taxpayers and others to defraud the United States, evade U.S. income taxes, and file false U.S. tax returns.  He remains at large.

DOYLE, 59, of New York, New York, is charged with one count of obstructing and impeding the due administration of the IRS laws, which carries a maximum sentence of three years in prison, and one count of subscribing to a false and fraudulent U.S. individual income tax return, which also carries maximum sentence of three years in prison.  The maximum potential sentences are prescribed by Congress and are provided here for informational purposes only, as any sentencing of the defendant will be determined by the judge.

U.S. Attorney Bharara praised the outstanding investigative work of IRS-CI and also thanked the U.S. Department of Justice’s Tax Division for their assistance.

The case is being prosecuted by the U.S. Attorney’s Office for the Southern District of New York’s Complex Frauds and Cybercrime Unit.  Assistant U.S. Attorney Jared Lenow is in charge of the prosecution.

The charges contained in the Indictment are merely accusations, and the defendant is presumed innocent unless and until proven guilty.