A former Credit Suisse Group AG client was charged with a tax-evasion conspiracy in the U.S. as officials weigh whether the bank — now owned by UBS Group AG — breached a 2014 plea deal in which it paid $2.6 billion and admitted helping thousands of Americans evade taxes.

Gilda Rosenberg, a Florida businesswoman, conspired with two family members in hiding $90 million in assets from the Internal Revenue Service between 2010 and 2017, federal prosecutors charged Wednesday. She’s accused of acting to conceal money in undeclared foreign accounts while also filing false returns and evading taxes on unreported income. 

The extent to which Credit Suisse complied with its plea deal took on new focus after a 2023 Senate Finance Committee report said there were “major violations” of its agreement that requires the bank to identify undeclared U.S. accounts to the IRS. In the report, Democratic staff on the committee said the bank had still failed to fully disclose US assets despite having identified “thousands of previously undeclared accounts” valued at more than $1.3 billion. 

In response to the report, Credit Suisse said it was cooperating and had provided information to U.S. authorities on potentially undeclared accounts held by American clients.

A spokesman for UBS declined to comment Thursday on the case against Rosenberg. An attorney for Rosenberg declined to comment.   

Telling the IRS

The 2023 report doesn’t name the Rosenbergs but describes how the bank allegedly helped a family of dual citizens of the U.S. and Latin American country evade taxes. Whistleblowers told the committee the family members held nearly $100 million at Credit Suisse for a decade before transferring those assets to other banks without telling the IRS. 

The charge against Rosenberg doesn’t identify Credit Suisse, but refer to the same allegations described in the Senate report, according to people familiar with the matter. U.S. authorities are weighing whether the Swiss bank breached the terms of its 2014 deal, said the people, who asked not to be identified discussing internal discussions.

UBS said in its third-quarter report that it had a provision for potential costs tied to inquiries into its cross-border wealth management services, including Credit Suisse’s compliance with the 2014 plea deal. It didn’t disclose an amount for the provision.

UBS could announce a settlement with prosecutors for violating terms of the 2014 deal as soon as this week, the Wall Street Journal reported on Thursday. The bank could agree to pay at least hundreds of millions of dollars, according to the report. The UBS spokesperson declined to comment on a possible settlement. 

Under its plea agreement with the U.S., Credit Suisse had to disclose all undeclared U.S. accounts closed and transferred from 2008 to 2014. Disclosing those account holders, known as “leaver lists,” was a U.S. requirement for Credit Suisse, several other Swiss banks that faced criminal charges, and 80 Swiss banks that made deals to avoid prosecution.

At the time of the report in 2023, Senator Ron Wyden, the Oregon Democrat who chairs the committee, slammed “greedy Swiss bankers” who appeared to be engaged in a “massive, ongoing conspiracy to help ultra-wealthy U.S. citizens to evade taxes.”

The report was released around the same time that Credit Suisse was being sold to rival UBS in a 3 billion franc ($3.3 billion) deal brokered by the Swiss government after years of scandal and mismanagement. 

‘Donate’ assets

Gilda Rosenberg was charged in a so-called criminal information. In a separate case last year, she pleaded guilty in Texas to conspiracy to commit wire fraud involving a Miami vending machine company she owns. She is scheduled to be sentenced on April 30. 

Rosenberg, a U.S. citizen, was born in Colombia and lives in south Florida, according to the tax charge. She conspired with two family members also born in Colombia, the U.S. alleges. They hid money in accounts in Switzerland, Spain, Israel and Andorra, prosecutors charged. 

Rosenberg and one relative agreed to sign documents purporting to “donate” assets in undeclared accounts to the other relative, the U.S. alleges. She also caused her return preparer to underreport income to the IRS and falsely say she had no interest in a foreign financial account, according to the charge.  

Since the bank’s 2014 guilty plea, other U.S. clients of Credit Suisse have been charged in tax cases. In 2016, Dan Horsky pleaded guilty to hiding more than $200 million in assets from the IRS. A Brazilian-American businessman, Dan Rotta, was indicted last year for allegedly using Credit Suisse, UBS and other Swiss banks to hide more than $20 million in assets from U.S. tax authorities over 35 years.

Due to extensive interest, Accounting Today has extended the deadline for submissions to its 2025 Top New Products report. Submissions, which were originally due Jan. 10, can now be made until the end of the day on Wednesday, Jan. 15.

The report will recognize the best new and significantly improved products aimed at tax and accounting professionals, as judged by the editors of Accounting Today.

Products for consideration must be designed for the tax and accounting profession; must have been released no earlier than January 2024; and must be currently available (i.e., not in beta testing) in the U.S. market.

Submissions must include:

• Release date;
• Pricing;
• A website URL and/or phone number for customer contact;
• 200 words or less describing the product’s functionality and its relevance to the tax and accounting profession; and
• A digital image or logo for the product, if available (images can be in JPG, EPS or TIFF format, at 300 dpi or higher).

We will accept up to three submissions per vendor, or three per major division of a vendor.

Submissions may be sent by email to our technology editor, Chris Gaetano, at [email protected],