Woman Gets Prison for Hiding Over $90M From the IRS in Overseas Accounts

The defendant and her relatives hid the funds in banks in Switzerland, Panama, Israel and Andorra, authorities said.

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A Florida woman with dual U.S. and Colombian citizenship has been sentenced to 2½ years in prison for concealing millions in foreign accounts and tax evasion, federal authorities announced.

From 2020 to 2022, Gilda Rosenberg of Golden Beach, Fla., concealed more than $90 million in assets and income held from the IRS in undeclared bank accounts in Switzerland, Panama, Israel and Andorra, according to a news release from the Justice Department. Rosenberg conspired with two family members in the scheme, authorities said.

Since the 1970s, Rosenberg’s family held offshore accounts, and she was listed as an owner and an authorized signer on some of the accounts. Rosenberg was aware starting in the 1990s that they had not disclosed the accounts to the U.S. government or paid taxes on them, according to the release.

The family consolidated their assets with Credit Suisse in Switzerland and the United Kingdom in the early 2000s and told the bank’s employees that they were hiding the assets from the U.S. government. Credit Suisse closed the accounts in 2013, citing that family members were Americans.

The family then moved the assets to Bank Leumi in Israel, Union Bancaire Privée (UBP), PKB Privat Bank SA in Switzerland, and an Andorran bank. Rosenberg was designated the beneficial owner of accounts at the bank in Andorra and UBP. When opening accounts, she falsely claimed she was a citizen of Colombia, not the United States.

Rosenberg and other family members failed to file required Reports of Foreign Bank and Financial Accounts (FBARS) that would disclose the overseas accounts. She and other family members filed fraudulent tax returns that failed to list revenue from the accounts.

In a continuing effort to evade U.S. taxes, Rosenberg and other family members in or around 2017 split the assets and signed papers to make it seem that she and another family member gave the offshore assets to another relative who had renounced U.S. citizenship.

She and others in the family attempted to secretly transfer assets back to her in America In an effort to conceal their tax evasion, Rosenberg and others created false loan and investment documents indicating that the money transfers were loans and business investments.

Rosenberg filed false tax returns from 2010 through 2017 that omitted income from the UBP account. The unreported income of Rosenberg and two others totaled more than $5.5 million, meaning they evaded paying $1,927,342 in taxes during that time, federal officials said.

Rosenberg agreed before sentencing to pay the IRS $1,927,342, plus interest. Rosenberg’s plea agreement also required her to pay $5,857,045 to the IRS for failing to file an FBAR.

Rosenberg has already pleaded guilty in Texas to conspiracy to commit wire fraud. In that case, she sought to defraud the Army and Air Force Exchange Service though false reporting to avoid fully paying contractually required commissions.

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