Miami Man Sentenced to 60 Months in Prison for Hiding Millions in Swiss Bank Accounts and Failing to Disclose Income to the IRS

A Miami man, Dan Rotta, was sentenced to 60 months in prison for conspiring to defraud the United States by concealing millions of dollars in assets and income in undisclosed Swiss bank accounts and claiming to the IRS that those assets were not his and instead belonged to foreign nationals. Between 1985 and 2020, Rotta hid more than $20 million in assets in dozens of secret Swiss accounts at five different Swiss banks, including UBS, Credit Suisse, Bank BonhÈ³te, and Bank Julius Baer. Rotta employed increasingly elaborate schemes to keep his accounts hidden, including falsely representing that he was not a U.S. citizen and leveraging his Brazilian citizenship to claim he was a Brazilian citizen residing in Brazil. Rotta also created sham trust structures and used nominee accounts to transfer his assets to the United States without alerting the IRS. In an attempt to avoid criminal liability, Rotta applied to participate in the IRS's voluntary disclosure practice, but made false statements in his submission.

Key Takeaways:

Dan Rotta, a dual Brazilian and U.S. citizen, was sentenced to 60 months in prison for conspiring to defraud the United States by concealing millions of dollars in assets and income in undisclosed Swiss bank accounts.
Between 1985 and 2020, Rotta hid more than $20 million in assets in dozens of secret Swiss accounts at five different Swiss banks.
Rotta employed increasingly elaborate schemes to keep his accounts hidden, including falsely representing that he was not a U.S. citizen and leveraging his Brazilian citizenship to claim he was a Brazilian citizen residing in Brazil.
Rotta created sham trust structures and used nominee accounts to transfer his assets to the United States without alerting the IRS.
In an attempt to avoid criminal liability, Rotta applied to participate in the IRS's voluntary disclosure practice, but made false statements in his submission.
Rotta was investigated by the IRS's International Tax & Financial Crimes specialty group, which is based out of Washington, D.C.
Acting Deputy Assistant Attorney General Karen E. Kelly of the Justice Department's Tax Division, U.S. Attorney Hayden O'Byrne for the Southern District of Florida, and Executive Special Agent in Charge Kareem Carter of IRS-CI Washington, D.C. Field Office made the announcement.

Statistics:

$20 million: the amount of assets hidden by Rotta in secret Swiss bank accounts.
5 banks: the number of Swiss banks where Rotta maintained his secret accounts.
2019: the year in which Rotta became aware that the IRS would receive additional account records from Switzerland that contradicted the false claims he had previously made.
60 months: the prison sentence given to Rotta for conspiring to defraud the United States.

Sources:

United States Attorneys General
IRS Criminal Investigation (IRS-CI) Washington, D.C. Field Office
Justice Department's Tax Division
U.S. Attorney's Office for the Southern District of Florida
IRS-CI's International Tax & Financial Crimes specialty group
Tax Division's Senior Litigation Counsels Sean Beaty and Mark Daly, Trial Attorney William Montague, and former Trial Attorney Patrick Elwell
Senior Litigation Counsel Christopher J. Clark for the Southern District of Florida