Roberto Cittadini, of Bellevue, was sentenced Friday, Jan. 8 in U.S. District Court in Seattle to six months of home detention, 200 hours of community service, a $10,000 fine and one year of supervised release for filing a false tax return. Last fall Cittadini pleaded guilty admitting he concealed nearly $2 million in Swiss bank accounts. According to court documents and statements made in court, Cittadini, a retired sales manager for Boeing, failed to report income from bank accounts under his control at UBS AG in Switzerland on his individual income tax returns from 2001 through 2003.
Additionally, Cittadini failed to file a Report of Foreign Bank and Financial Accounts (F-BAR) for each of these years. At sentencing U.S. District Judge Ricardo S. Martinez said it was clear that Cittadini understood the consequences that come from being a convicted felon. Judge Martinez ordered the community service saying it was “a better way to repay your community.”
According to court documents and statements made in court, Cittadini initially opened an account with UBS in the early 1990s in his own name. In approximately 2001, Swiss banker Hansruedi Schumaker, who was indicted in August 2009 for conspiring to defraud the United States, assisted Cittadini in transferring the assets from his UBS account to an account held in the name Mataropa Finance Limited, a nominee Hong Kong corporation.
Cittadini transferred his assets to the Hong Kong entity to evade U.S. reporting and withholding requirements. Additionally, Swiss lawyer Matthias W. Rickenbach, who also was indicted in August 2009, acted as the director of the Hong Kong nominee corporation. From 2001 through 2003, Cittadini held as much as $1.86 million in assets in the Mataropa Finance Limited account at UBS in Switzerland.
As part of his plea agreement, Cittadini agreed to pay a civil F-BAR penalty based on 50 percent of the highest account balance from 2001 to 2007. In court Friday Cittadini’s attorney stated that Cittadini had paid taxes, interest and penalties last week totaling about $975,000.
Speaking in court, Cittadini said his actions had “thrown a cloak of shame on his family name,” and said he could only blame himself. He said pleading guilty to the felony and the consequences “has been devastating.”
In February 2009, UBS entered into a deferred prosecution agreement in which the bank admitted to helping U.S. taxpayers hide accounts from the IRS. As part of their agreement, UBS provided the United States government with the identities of, and account information for, certain U.S. customers of UBS’s cross-border business.
United States citizens who have an interest in, or signature or other authority over, a financial account in a foreign country with assets in excess of $10,000 are required to disclose the existence of such account on Schedule B, Part III of their individual income tax return. Additionally, American citizens must file an F-BAR with the U.S. Treasury, disclosing any financial account in a foreign country with assets in excess of $10,000 for which they have a financial interest in or signature authority, or other authority over.