As expected, in tax filing season, DOJ Tax takes actions to encourage taxpayers to do the right thing. There are two HSBC India developments. We previously covered the John Doe summons to HSBC India here. The new developments are:
1. One depositor in HSBC India, Vaibhav Dahake, who was indicted previously (see discussion of indictment here). Dahake pled guilty to one count of conspiracy on April 11, 2011 pursuant to a plea agreement he had entered November 18, 2010. (I speculate that the timing of the actual plea in court was related to the HSBC John Doe summons proceeding, or, perhaps, had something to do with the HSBC related enablers.) The plea agreement is here, and a Reuters article is here. The plea agreement is fairly standard, with the stipulated sentencing factors being: (i) a tax loss between $30,000 and $80,000 producing a BOL of 14, (ii) sophisticated means 2 level upward adjustment, (iii) acceptance of responsibility 3 level (2+1) downward adjustment and (iv) deriving an offense level of 13. One unusual provision is the following related to immigration:
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