A Brazilian-American businessman who lives in Florida was charged with using Credit Suisse Group AG, UBS Group AG and other Swiss banks to hide more than $20 million in assets from US tax authorities over 35 years.
Dan Rotta, 77, was arrested on March 9 at Miami International Airport as he was preparing to fly to Barcelona, according to people familiar with the matter. He appeared Monday in Miami federal court, where a magistrate judge said he should remain in jail until a hearing on Tuesday morning, according to court officials.
The Justice Department is trying to determine whether Credit Suisse breached a 2014 plea agreement in which it paid $2.6 billion and admitted helping thousands of Americans evade taxes. Rotta hid assets from the IRS in two-dozen secret bank accounts between 1985 and 2020, according to court documents.
Over the years, “Rotta deliberately sought to hide his offshore assets and income behind pseudonyms, complicated corporate structures, and nominees,” an Internal Revenue Service special agent wrote in an affidavit.
An attorney for Rotta declined to comment. Rotta, who lives in Fisher Island, was charged with conspiring to defraud the US and making false statements to the IRS. He faces as many as five years in prison on each count if convicted.
A spokesperson for UBS, which now owns Credit Suisse, didn’t immediately respond to a request for comment. In a regulatory filing last month, UBS said: “Credit Suisse AG has provided information to US authorities regarding potentially undeclared US assets held by clients at Credit Suisse AG since the May 2014 plea. Credit Suisse AG continues to cooperate with the authorities.”
Bloomberg News earlier reported that US prosecutors are conducting grand jury investigations to determine whether former Credit Suisse customers engaged in tax fraud. The story referred to a businessman whose Fisher Island residence was raided by the IRS in 2021. Rotta was the customer, the people said.
The arrest affidavit said that after public reports surfaced in 2008 that UBS was under investigation for helping US taxpayers evade taxes, Rotta closed his account at the bank and moved assets to another Swiss bank. Rotta, a citizen of the US, Brazil and Romania, didn’t identify himself as an American taxpayer.
He was a client of Beda Singenberger, a Swiss financial adviser charged a decade ago with helping 60 people in the US hide $184 million in secret offshore accounts with names like Real Cool Investments Ltd. and Wanderlust Foundation.
Rotta had other brushes with the law. In 2012, a judge ordered him to serve 180 days for contempt of court after defying a directive to take his 16-year-old son to a Utah boarding school. Instead, Rotta took him to Las Vegas to marry his housekeeper’s daughter, according to media accounts at the time.
Edelwiss, Putzo Foundation
IN the US tax case, Rotta used entities like a British Virgin Islands corporation called Edelwiss Corporate Ltd. and the Putzo Foundation in Liechtenstein, according to the complaint. The IRS began auditing Rotta in 2011 after obtaining evidence he had unreported foreign financial accounts, and he denied owning them.
He claimed that hundreds of thousands of dollars in transfers from foreign accounts were non-taxable loans, and enlisted a cousin from Brazil to tell the IRS he made or facilitated the fake loans, the US said.
After the IRS assessed additional taxes and penalties against Rotta, he petitioned the US Tax Court and denied having any foreign accounts. The cousin came to the US to “retell the false loan story to IRS attorneys,” the US said.
In 2019, Rotta tried to make a voluntary disclosure to the IRS to limit his exposure to criminal prosecution and fraudulently limit his exposure to a potential $10 million penalty. But his application was full of false statements, according to the complaint. Bloomberg