Gilda Rosenberg, Tax Evasion, Florida 2024

Florida woman Gilda Rosenberg was sentenced to 30 months in prison for conspiring to defraud the United States by concealing tens of millions of dollars in undeclared foreign financial accounts, filing false tax returns, and evading taxes.

Rosenberg, a dual U.S. and Colombian citizen, was identified as an owner and an authorized signer on some of the accounts. Her family had maintained offshore accounts since the 1970s. By the late 1990s, Rosenberg knew that she and her family members had not disclosed their ownership of these foreign financial accounts to the U.S. government and that they had not paid any taxes on the income earned from the assets in those accounts as was required by law.

The family consolidated their assets at accounts with Credit Suisse in Switzerland and the United Kingdom starting in the early 2000s. Family members told Credit Suisse employees that they were U.S. persons and seeking to hide their assets from U.S. authorities. The assets remained at Credit Suisse until 2013, when Credit Suisse closed the accounts because the family members were U.S. persons.

Rosenberg was sentenced in the Southern District of Florida on Friday, April 19, 2024. She pleaded guilty in the Eastern District of Texas to an information charging her with conspiracy to commit wire fraud related to a scheme to defraud the Army and Air Force Exchange Service. Rosenberg also agreed to pay $1,927,342 in restitution to the IRS and a penalty of $5,857,045.50 to the IRS to resolve her civil liability for failing to file an FBAR.

The family moved their assets to new accounts located at Bank Leumi in Israel, Union Bancaire Privée (UBP) and PKB Privat Bank SA in Switzerland, and an Andorran bank. Rosenberg was documented as the beneficial owner of accounts at UBP and the Andorran bank. She also signed false account opening documents that claimed she was a Colombian citizen and not a U.S. citizen.

Rosenberg and her relatives did not file Reports of Foreign Bank and Financial Accounts (FBARS) disclosing their foreign financial accounts, as they were required to do. In addition, Rosenberg and her relatives continued to file false tax returns that omitted income generated by their offshore assets. From 2010 through 2017, Rosenberg filed false tax returns that did not report income she earned from assets in the account she concealed at UBP. For the 2009 through 2017 tax years, unreported income belonging to Rosenberg and two of her co-conspirators totaled more than $5.5 million, causing a tax loss of $1,927,342.

Related Federal Cases