A Miami resident has admitted to a decades-long conspiracy to defraud the United States by hiding millions of dollars in Swiss bank accounts. Dan Rotta pleaded guilty to charges that span from 1985 to 2020, involving more than $20 million in undisclosed assets across several Swiss banks, including UBS and Credit Suisse.
According to court documents, Rotta did not report the income generated from these assets on his tax returns. Instead, he used the funds to maintain an extravagant lifestyle while causing significant tax losses for the IRS.
Rotta allegedly utilized complex schemes over the years, including misrepresenting his citizenship status and creating sham structures. After news broke in 2008 about UBS aiding U.S. taxpayers in evading taxes, Rotta transferred his funds from UBS to other Swiss banks.
In 2011, as the IRS began scrutinizing one of his accounts, Rotta altered account documentation to falsely indicate ownership by a co-conspirator residing in Brazil. Despite this change, he maintained control over the funds and continued using them for personal purposes.
During an IRS audit, Rotta denied owning foreign financial accounts and presented false evidence of non-taxable loans from foreign nationals. He routed money through nominee accounts within the United States to obscure its origins.
The IRS challenged these claims and assessed additional taxes and penalties against him. Rotta countered with a false petition in U.S. Tax Court but eventually convinced authorities that purported loans had been repaid—though these repayments were fictitious.
In 2019, anticipating further scrutiny from newly available Swiss records contradicting his previous claims, Rotta attempted to mitigate criminal liability by applying for voluntary disclosure with the IRS. However, he submitted false statements during this process as well.
Sentencing is scheduled for June 4th; Rotta faces up to five years imprisonment. A federal district court judge will determine any sentence after reviewing relevant guidelines and statutory factors.
U.S. Attorney Hayden P. O’Byrne announced the plea along with Karen E. Kelly from the Justice Department’s Tax Division and Kareem Carter of IRS Criminal Investigation (IRS-CI). The case is being investigated by special agents specializing in international tax crimes based out of Washington D.C., while prosecution is led by Senior Litigation Counsel Christopher J. Clark alongside others from Florida's Southern District and Tax Division attorneys Patrick Elwell and William Montague.
Further information can be accessed through Florida's Southern District Court website or PACER under case number 24-cr-20113.