'John Doe' summons continues to widen reach of IRS

A ‘John Doe’ summons has been issued seeking information about US taxpayers who may hold offshore accounts with FirstCaribbean International Bank (FCIB), a subsidiary of Canadian Imperial Bank of Commerce. While FCIB has no branches in the US, it has a correspondent account with US-based Wells Fargo. Financial transactions involving US dollars have to flow through US banks. In order for foreign banks with no US office to do business in US dollars they have to obtain a correspondent account at a US bank. These correspondent bank accounts have records of money deposited, money paid out th...