Hayden O’Byrne United States Attorney for the Southern District of Florida | The Florida Bar
A Miami resident, Dan Rotta, has admitted to conspiring with others to defraud the United States by hiding millions in undisclosed Swiss bank accounts. According to court documents and statements, from 1985 to 2020, Rotta concealed over $20 million across various Swiss banks such as UBS and Credit Suisse. He reportedly earned significant income from these assets without reporting them on his tax returns.
Rotta employed complex methods to keep his accounts hidden, including misrepresenting his citizenship status. After reports surfaced in 2008 of criminal investigations into UBS for aiding U.S. taxpayers in evading taxes, Rotta moved his funds from UBS to other banks like Credit Suisse.
In 2011, when the IRS obtained records of one of his Swiss accounts, Rotta altered account documentation to suggest a Brazilian co-conspirator owned the assets. Despite this change, he maintained control over the accounts and transferred large sums for personal use.
During an IRS audit, Rotta falsely denied owning foreign assets and claimed that withdrawals were non-taxable loans from foreign nationals. He provided fake documents to support these claims while continuing to fund his lifestyle through these accounts.
The IRS assessed additional taxes against him, which he challenged by filing a false petition in U.S. Tax Court. In 2017, after presenting false evidence of loan repayments, the IRS reversed its assessment.
In 2019, anticipating further scrutiny from the IRS regarding new account records from Switzerland, Rotta attempted to participate in the IRS's voluntary disclosure program but submitted false information.
Rotta is scheduled for sentencing on June 4 and faces up to five years in prison. The case was announced by U.S. Attorney Hayden P. O’Byrne for the Southern District of Florida along with other officials from the Justice Department’s Tax Division and IRS Criminal Investigation.
Special Agents from IRS-CI’s International Tax & Financial Crimes group are leading the investigation with prosecution led by Senior Litigation Counsel Christopher J. Clark among others.
Further information can be found on the website of the District Court for the Southern District of Florida under case number 24-cr-20113.
