DOJ Tax and Mizrahi-Tefahot Bank Ltd. (Israel) Reach DPA (3/13/19)

DOJ Tax announced here the DPA with Mizrahi-Tefahot Bank Ltd., (Mizrahi-Tefahot) and its subsidiaries.  I have not been able to find the underlying documents, but from the Press Release, I think the following are the key items:

• "In the DPA and related court documents, Mizrahi-Tefahot admitted that from 2002 until 2012 the actions of its bankers, relationship managers, and other employees defrauded the United States and specifically the Internal Revenue Service (IRS) with respect to taxes by conspiring with U.S. taxpayer-customers and others. Mizrahi-Tefahot employees’ acts of opening and maintaining bank accounts in Israel and elsewhere around the world and violating Mizrahi-Tefahot’s Qualified Intermediary Agreement (QI Agreement) with the IRS enabled U.S. taxpayers to hide income and assets from the IRS."  [This apparently is the defraud / Klein conspiracy.]
• Mizrahi admits the standard range of conduct by foreign banks playing in this field.
• "The DPA also requires Mizrahi-Tefahot and its subsidiaries affirmatively to disclose certain material information it may later uncover regarding U.S.-related accounts, as well as to disclose certain information consistent with the Department’s Swiss Bank Program with respect to accounts closed between Jan. 1, 2009, and October 2017."  [For that reason, I have included Mizrahi in the Category 1 for the DOJ Swiss Bank Program; Mizrahi is not technically within the program but did have a Swiss subsidiary.]
• Mizrahi will pay $195 million total, consisting of "1) restitution in the amount of $53 million, representing the approximate unpaid pecuniary loss to the United States as a result of the criminal conduct; 2) disgorgement in the amount of $24 million, representing the approximate gross fees paid to the bank by U.S. taxpayers with undeclared accounts at the bank from 2002 through 2012; and 3) a fine of $118 million."

DOJ Tax had previously offered $342 Million to settle:  Mizrahi-Tefahot Bank Rejects DOJ $342 Million Settlement Offer for NPA (Federal Tax Crimes Blog 8/10/18), here.

US DOJ Swiss Bank Program	Number	Resolved	Total Costs
U.S. / Swiss Bank Initiative Category 1 (Criminal Inv.) *	19	9	$4,376,733,560
U.S. / Swiss Bank Initiative Category 2	87	81	$1,368,983,990
U.S. / Swiss Bank Initiative Category 3	13		$0
U.S. / Swiss Bank Initiative Category 4	8		$0
Swiss Bank Program Results	127		$5,745,717,550
* Number and Number Resolved may not be same as DOJ and IRS numbers because of how related entities were counted; the Total Costs Column should be consistent.
Recoveries from Swiss Financial and Related Institutions (per above)			$5,745,717,550
Recoveries from NonSwiss Offshore Financial and Related Institutions			$298,770,542
Recoveries from All Offshore Financial and Related Institutions			$6,044,488,092

Mizrahi-Tefahot Bank Rejects DOJ $342 Million Settlement Offer for NPA (8/10/18)

A reader linked to this article:  Shoshanna Solomon, Mizrahi-Tefahot Bank rejects $342 million US fine to settle tax evasion probe (The Times of Israel 8/8/18), here.

I hesitate to do excerpts because the article is short and has good information throughout.  Still, here are some excerpts as a teaser:

In a filing to the Tel Aviv Stock Exchange late Tuesday, the bank said that it received a notice from the US Justice Department that it is willing to close the investigation if the bank agrees to pay a fine of $342 million. 

The letter from the representative of the US Justice Department stated the amount without any indication of how it was reached, the bank said in the filing. The letter also included a draft factual document that could be used as a basis for a Deferred Prosecution Agreement, with the aim of negotiating the terms of an agreement, the filing said. 

The board of directors instructed the bank’s attorneys to inform the US authorities that they reject the offer, saying that any amount to be paid to the US regulators should be “significantly lower” than the amount suggested. To date, the bank has set aside some $45 million to cover a potential settlement with the US authorities. 

* * * * 

US authorities targeted three Israeli banks with investigations regarding tax evasion in the US by customers. In 2014, Bank Leumi Le-Israel Ltd. agreed to pay some $400 million to US regulators to settle a criminal probe after admitting it helped US taxpayers hide assets. Investigations by US regulators into Bank Hapoalim Ltd. and Bank Mizrahi-Tefahot Ltd. are ongoing. 

As of February, Israel’s Bank Hapoalim had set aside some $343 million for the investigation, warning that the overall exposure could be even higher.

Mizrahi Tefahot Bank U.S. Banker Acquitted (11/2/14)

A  Mizrahi Tefahot Bank Ltd. banker has been acquitted of conspiracy, the only charge against him.  See David Voreacos, Ex-Mizrahi Octogenarian Banker Acquitted at Tax Trial (Bloomberg 11/1/14), here.  Key excerpts:

Prosecutors claimed Baravarian helped clients who opened accounts in Israel, didn’t declare them to the IRS and accessed money through loans from the Los Angeles branch. 

Six taxpayers testified as government witnesses, including three who pleaded guilty and two who avoided prosecution by entering an IRS disclosure program. On cross-examination, all six admitted they didn’t conspire with Baravarian to cheat on their taxes, defense attorney Marc S. Harris said. 

“These taxpayers did what they did on their own, and they didn’t pay taxes on their accounts,” Harris said. “Dr. Baravarian had nothing to do with that. The linchpin of the case was that the loans were fake, and they were a mechanism to access that money. Dr. Baravarian helped people get legitimate loans for legitimate purposes.”

Thanks to Dave Wolf for calling this to my attention.

Mizrahi Tefahot U.S. Banker Indicted for Enabling Offshore Accounts (4/31/14)

Shokrollah Baravarian, of Beverly Hills, California, a former Mizrahi Tefahot Bank Ltd. banker, was indicted for conspiracy in California.  See DOJ press release here.  Here are the key excerpts:

According to the indictment, Baravarian, a former senior vice president at the Los Angeles branch of a bank headquartered in Tel Aviv, Israel, conspired to conceal the existence of undeclared accounts owned and controlled by U.S. customers in Israel.  The indictment alleges that these accounts were concealed from the IRS by opening them under pseudonyms, code names and the names of nominee entities set up in the British Virgin Islands and the island of Nevis. 

* * * * 

“The defendant assisted others to hide the true ownership of offshore bank accounts through the use of code names and nominee entities,” said Chief of IRS-Criminal Investigation Richard Weber.  “Our special agents unraveled the complex financial transactions used to disguise the funds in the undeclared accounts.  Those who help others commit tax evasion risk prosecution and substantial monetary penalties.” 

 The indictment further alleges that Baravarian assisted U.S. customers in secretly accessing the funds in their undeclared accounts by obtaining back-to-back loans from the Los Angeles branch of the bank.  According to the indictment, a back-to-back loan was a loan that was secured by funds in an undeclared account in Israel and issued by the Los Angeles branch to a U.S. customer.  Baravarian is alleged to have helped conceal the fact that U.S. customers were using their own funds as collateral by purposely not keeping copies of loan-related documents in the files at the Los Angeles branch.  These documents included Israeli account information and pledge agreements used to secure the loans.  As detailed in the indictment, some U.S. customers obtained back-to-back loans from the Los Angeles branch by transferring funds to Israel from other foreign countries, including Switzerland and China. 

 The indictment further alleges that a banker in Israel would periodically travel to Los Angeles and meet with U.S. customers to discuss their account statements.  Prior to making these trips, the banker would redact the names of the U.S. customers reflected on the account statements. 

Israeli Banks Advised to Prepare for FATCA Before Negotiations Finalized (3/19/14)

Although the U.S. and Israel are in negotiations, it appears the endgame is in sight.  See Banks told to prepare for new reporting rules on U.S. clients (Haaretz 3/19/14), here.  Key initial except::

The Bank of Israel Sunday advised Israeli banks to begin gearing up to provide information about their U.S. clients to U.S. tax authorities, as provided in the U.S. Foreign Tax Compliance Act. 

The statement was issued by the central bank in an effort to ensure that Israeli banking institutions will be ready to comply with FATCA when it goes into effect, in July. The purpose of the act is to help U.S. authorities collect any taxes owed by U.S. citizens, wherever they may live, with accounts at banking institutions outside the United States. 

Israeli banks are subject to laws in Israel, and not to U.S. laws such as FATCA. Until now, Israeli banks were obliged to protect their customers’ privacy and were forbidden from providing information on account holders to any parties unless Israeli regulators explicitly stated otherwise. 

The banks had expected Israel’s central bank to push them to comply with the U.S. crackdown, though. Doing otherwise could expose the banks to U.S. sanctions, including limits on their branches within the United States. 

Sunday’s order brought Israel’s banking system in line with many others that have given in to American demands, including Switzerland’s banks, which had been well-known for their privacy. 

As far as is known, the step was taken following advanced negotiations between Israeli government officials and their U.S. counterparts. The bilateral deal would include an Israeli commitment to provide the required information about the American customers of Israeli banks. In return, the United States is expected to commit to provide the Israeli government with comparable data on U.S. banks’ Israeli customers. 

Most Israeli banks have been preparing for two years for the introduction of FATCA in Israel, informing their U.S. customers about the anticipated requirement and its implications. 

It is assumed that any U.S. citizen seeking to evade the reporting requirements has already withdrawn their funds from Israeli banks and turned to other investment channels, such as Israeli real estate, which is not subject to regulation under FATCA. Others have voluntarily disclosed their assets to the U.S. Internal Revenue Service.

Dave Wolf, an Isreali lawyer, advises here that (emphasis supplied by JAT):

This development is quite surprising as usually countries sign the FATCA agreement first before starting the implementation of FATCA rules. 

The negotiations with the USA have been ongoing a very long time and this may be partly the result of the U.S. Department of Justice criminal investigation into the behavior of three Israeli banks in Switzerland: Bank Leumi, Bank Hapoalim and Bank Mizrahi.

Mizrahi Bank Client Pleads for Filing False Tax Return (2/14/14)

Monajem Hakimijoo, a Beverley Hills resident, pleaded to one count of tax perjury arising from an undisclosed foreign account held with Mizrahi Bank through a Turks and Caicos entity.  The DOJ Tax press release is here.  Key excerpts from the press release:

        According to court documents, Hakimijoo, a U.S. citizen, and his brother maintained an undeclared bank account in Israel at Mizrahi Bank in the name of Kalamar Enterprises, a Turks and Caicos Islands entity they used to conceal their ownership of the account.  Hakimijoo and his brother used the funds in the Kalamar account as collateral for back-to-back loans obtained from the Los Angeles branch of Mizrahi Bank.  Although Hakimijoo and his brother claimed the interest paid on the back-to-back loans as a business deduction for federal tax purposes, they failed to report the interest income earned in their undeclared, Israel-based account as income on their tax returns.  In total, Hakimijoo failed to report approximately $282,000 in interest income.  The highest balance in the Kalamar Enterprises account was approximately $4,030,000.

        According to court documents, in March 2013, Hakimijoo was scheduled to be interviewed by Justice Department attorneys and IRS special agents.  Prior to the interview, Hakimijoo, through counsel, provided the attorneys and special agents with copies of his amended tax returns for 2004 and 2005.  When asked if the amended tax returns had been filed with the IRS, Hakimijoo indicated that the returns had been filed.  Shortly thereafter, the IRS determined there was no record of the amended returns being filed with the IRS.  When Hakimijoo was asked to provide copies of cancelled checks to prove that the taxes reflected on the amended returns had been paid, none were provided.

        Hakimijoo is the latest in a series of defendants charged in the U.S. District Court for the Central District of California with concealing undeclared bank accounts in Israel that were used to obtain back-to-back loans in the United States.

* * * *

            Hakimijoo will be sentenced on April 28, 2014, and faces a statutory maximum prison term of three years and a maximum fine of $250,000.  In addition, Hakimijoo has agreed to pay a civil penalty to the IRS in the amount of 50 percent of the highest balance of his one-half interest in the Kalamar account.

My off the cuff comment is that the amended return gambit was incredibly stupid.  But then we don't know all the facts, and he is not pleading to a false statement charge.

Swiss Settlement May Be Near (5/28/13)

Lynnley Browning, Switzerland Weighs Deal in Tax Cases (NYT DealBook 5/28/13), here, reports that a deal between the U.S. and Swiss may be near that might cover most of the outstanding issues.  Excerpts are:

The Swiss government is considering a proposal to disclose bank client names and pay a multibillion-dollar fine to the United States to help resolve a long-running dispute between the two countries over the handling of tax-evasion cases, American and Swiss sources briefed on the matter said on Tuesday. 

The fine, which could reach at least $7 billion to $10 billion according to these people, could be paid in part by the Swiss government, which would then seek reimbursement from the banks. 

* * * * 

The Swiss banks that have been the targets of investigations include Credit Suisse, which disclosed in July 2011 that it had received a letter saying it was under a grand jury investigation; the Zurich-based Julius Bär; two cantonal, or regional, banks; the Swiss operations of HSBC Holdings; and three Israeli banks, Hapoalim, Mizrahi-Tefahot Bank and Bank Leumi. 

* * * * 

Members of the top echelon of the Swiss government known as the Federal Council are expected to discuss the matter as early as Wednesday, according to people briefed on the talks. These people asked to be unidentified because the discussions were continuing.
Hans Kaufmann, a Swiss parliamentarian and member of the conservative Swiss People’s Party, said that various levels of Parliament would be informed of the Federal Council’s decision in stages over the next 10 days or so.

Article Targeted to Jewish Readers As A Result of Israeli Bank Developments (3/16/13)

Readers already know that, now that the Government is doing, in some respects, a mop-up operation for Swiss Banks (plenty to come, but the sights are set), the Government is focusing on banks in other countries -- now particularly Israel.  See the links to Bank Leumi and Mizrahi-Tefahot Bank in the links below.  A reporter for the New Jersey Standard recently interviewed Larry Horn, here, a prominent lawyer heavily involved in the offshore account practice, regarding this initiative.  Larry Yudelson, Time to Come Clean (New Jersey Jewish Standard 3/15/13), here.  Key excerpts are:

Another indication that Bank Leumi is under investigation by U.S. authorities — and may be disclosing account holders to American tax authorities — came last week, when the bank said it set aside $90 million to cover costs for the investigation. In February, an Israeli-born Los Angeles businessman struck a plea deal concerning $4 million hidden in overseas banks — reported to be Bank Leumi and Mizrahi Tefahot Bank. 

“Once the bank gives your name to the IRS, you’re disqualified” from entering the disclosure program, Horn said. “If you’re under an audit, under examination, or the bank has disclosed your name, you can’t enter the program.” 

Another indication that Bank Leumi is under investigation by U.S. authorities — and may be disclosing account holders to American tax authorities — came last week, when the bank said it set aside $90 million to cover costs for the investigation. In February, an Israeli-born Los Angeles businessman struck a plea deal concerning $4 million hidden in overseas banks — reported to be Bank Leumi and Mizrahi Tefahot Bank.
“Once the bank gives your name to the IRS, you’re disqualified” from entering the disclosure program, Horn said. “If you’re under an audit, under examination, or the bank has disclosed your name, you can’t enter the program.” 

* * * *  

He warns that prison terms are a possibility for people who get caught up in the IRS’ dragnet — particularly if they’ve been hiding accounts worth a million dollars or more.
At that level, unreported taxes on interest earned by the accounts can equal tens or hundreds of thousands of dollars — and that rises to the level of criminal tax evasion and possibly three years in prison.

Bank Leumi and Mizrahi-Tefahot Reportedly Under U.S. Criminal Investigation (2/19/13)

I reported Saturday on a plea agreement involving a U.S. customer of Bank Leumi (Bank B in the plea agreement) and Mizrahi-Tefahot Bank (Bank A in the plea agreement).  See New Plea Agreement Involving Israeli Banks (2/15/13), here.  Today, a Bloomberg reporter, David Voreacos, follows through his early news report on that plea with a new report, perhaps implicit in the earlier one, that these banks are getting focused attention of U.S. criminal tax enforcement authorities and specifically a federal grand jury.  See
David Voreacos, Bank Leumi, Mizrahi Clients Said to Aid U.S. Tax Probe (Bloomberg 2/19/13), here.

As usual, readers should read Mr. Voreacos' entire article.  Here are some excerpts that caught my attention.

Dozens of U.S. citizens who used offshore accounts to avoid taxes have helped the federal government in a criminal investigation of two Israeli banks, Bank Leumi Le-Israel Ltd. and Mizrahi Tefahot Bank Ltd., two people familiar with the matter said. 

* * * * 

“Those two banks are under investigation for making loans to permit their depositors to repatriate undeclared, offshore assets to the U.S.,” said Robert Fink, a tax attorney at Kostelanetz & Fink LLP in New York who represents clients who have come forward. “The focus is on undeclared foreign bank accounts on which income has been earned that has not been reported to the IRS.”

New Plea Agreement Involving Israeli Banks (2/15/13)

According to reports, Zvi Sperling pled guilty to a conspiracy count related to offshore accounts.  The Plea Ageement is here and the Sperling Information is here.

Key Facts


Defendant:  Sperling, Zvi
Conviction (by Plea):  Conspiracy (One Count)
Banks:  Bank Leumi (Bank B),  Mizrahi-Tefahot Bank (Bank A)
Entities:  Yes (Orot Investments Ltd, incorporated in Island of Nevis)
Tax Loss;  $30,000 - $80,000 range (this is a Sentencing Guideline Range)
FBAR Penalty: 50% of high balance
Court:  CD CA
Judge:


The article making the report is David Voreacos & Tom Schoenberg, Bank Leumi Said to Help California Man Cheat IRS, here. Some cuts and pastes from Mr. Voreacos' article are:

A California man agreed to plead guilty to conspiring with people at Bank Leumi Le-Israel Ltd. and Mizrahi Tefahot Bank Ltd. to hide offshore accounts and income from the U.S. Internal Revenue Service, according to court filings and people familiar with the matter. 

Zvi Sperling was accused Feb. 14 by federal prosecutors in Los Angeles of conspiring with people at two Tel Aviv-based banks, identified only as Bank A and Bank B. The charging document and plea agreement didn’t identify the banks. Bank A is Mizrahi, according to a person who wasn’t authorized to speak publicly about the case. Bank B is Leumi, according to a second person, who asked not to be identified for the same reason. 

* * * * 

“Sperling wanted to keep the money secret from the United States government and Banker 1 ensured that the money would be secret at Bank A in Israel,” according to the agreement. “Banker 1 also explained that Sperling would use the money by borrowing against the money at Bank A in the United States.”

Many more details are in the article.

Facts (fairly typical in their pattern):

1. The conspiracy related to the Israeli Banks started in 2001.  Existed with other banks prior to that date.
2. Israeli banks as of 2001, principally Bank A.
3. Bank A had U.S. offices where certain of the documents (back-to-back loans) were effected. The back-to-back loans were apparently loans secured by the secret Israeli accounts.  When Bank A closed its U.S. office, Bank B then pitched that it could do such loans and keep the foreign accounts secret  better than Bank A.  The funds were moved to Bank B.
4. A foreign entity was used, Orot Investments Limited, an Island of Nevis corporation.
5. An Israeli attorney, Attorney 1, was used 
6. Bankers 1 through 5, of Bank A, are mentioned in the information.
7. Representatives of Bank A met with defendant in the U.S. to discuss the opening of the account and thereafter traveled to U.S. to discuss the account

Plea Agreements:

1. Cooperation agreements: Defendant agrees to (i) "cooperate cooperate fully with the USAO, the Internal Revenue Service, and, as directed by the USAO, any other federal, state, local, or foreign prosecuting, enforcement, administrative, or regulatory authority;" and (ii) pay civil fraud penalty for years 2006 through 2011 on on his beneficial interest in unreported income from all funds held through foreign accounts; (iii) pay 50% on his interest in Bank Account A accounts.
2. Nonprosecution agreements:  Will not prosecute "Jacob Sperling, Shelly Sperling, and Miri Sperling"
3. Sentencing Factors:

   a.  Tax Loss:  $30,000 - $80,000, with indicated SG Guidelines  Offense Level of 14.
   b.  Sophisticated Means Enhancement:  +2
   c.  Acceptance of Responsibility Adjustment:  -2 or -3.
   d.  Potential for 5K1 departure.  (This means that he is cooperation with respect to others, including possibly his brother and the Israeli Banks)

Bank Leumi Signals Cooperation with U.S. on Offshore Accounts (1/11/13)

Reuters reports on developments with Bank Leumi, an Israeli bank.  Lynnley Browning, Bank Leumi sends letter to U.S. customers about IRS program (Reuters 1/10/13), here.

Excerpts:

Bank Leumi, the largest commercial bank in Israel, has urged U.S. clients to disclose information about their accounts to U.S. authorities, who are investigating Leumi and many other foreign banks over possible tax avoidance by Americans. 

In a Dec. 16 letter obtained by Reuters, Bank Leumi le-Israel BM urged U.S. clients to enter the Internal Revenue Service's voluntary disclosure program, part of a wide-ranging U.S. crackdown on offshore tax dodging. 

* * * * 

As previously reported by Reuters, Leumi and two other Israeli banks, Bank Hapoalim and Mizrahi-Tefahot , are under investigation by the U.S. Justice Department in connection with offshore private banking services that may have enabled wealthy Americans to evade taxes. 

* * * * 

Bryan Skarlatos, a New York tax lawyer with Leumi clients who got the letter, said it "is the result of ratcheted up pressure on Bank Leumi." He said U.S. officials "are asking clients questions about Leumi accounts: who the bankers were, what they said, did they come to the U.S., whose idea was it." 

* * * * 

Jeffrey Neiman, a criminal defense lawyer and former federal prosecutor who was involved in the UBS case, said U.S. officials are eager to expand their push beyond Switzerland, "and the Israeli banks have whetted their appetite."

 Also, some quotes from Shamik Trivedi, Israeli Bank's Letter Seen as Step Toward Turning Over Account Data, 2013 TNT 9-5 (1/14/13) (emphasis supplied):

Leumi is one of three Israeli banks under investigation by the Justice Department. In September the DOJ announced it was looking into allegations of tax evasion conspiracy by the Swiss branches of Leumi and two other Israeli banks, Bank Hapoalim and Bank Mizrahi-Tefahot. * * * *

Robert S. Fink of Kostelanetz & Fink LLP said it is his understanding that Leumi is negotiating with the Justice Department and that it has a tentative agreement to hand over the account information of U.S. persons, but is attempting to extract some promises from the government regarding the bank's liability and the liability of bank employees. 

* * * * 

Unlike Wegelin, which had only a correspondent account with UBS in Stamford, Conn., Leumi has offices in New York, California, Florida, and Illinois. 

* * * * 

* * * * Under FAQ 21 of the OVDP's frequently asked questions , the IRS maintains the right to exclude from the voluntary disclosure program taxpayers who have or had accounts at specific banks. The IRS has not yet announced which taxpayers, if any, fall into that category. 

* * * * 

Fink said that for taxpayers, the situation is now essentially "a race to the courthouse" with the IRS, meaning that a taxpayer has to submit his or her package under the OVDP before the IRS receives that information from the bank. * * * *

"Those who know what's happening realize that this is a precursor," and that the next letter sent by the bank might say that the names have been given or are about to be given, he [Fink] said.

Of course, once the bank gives up information on a U.S. taxpayer, it is too late to get assurance of the benefits of OVDP 2012, particularly no criminal prosecution.

Article on Israeli Banks as Targets in Tax Probe (6/8/12)

Asher Rubinstein, bio here, and a Julie Otten, an associate in Asher's firm, have written an article on the Government targeting Israeli banks, Asher Rubinstein, Esq. and Julie Otton, The Next Wave of IRS Offshore Account Enforcement: Israeli Banks Under Scrutiny (Ribinstein & Rubinstein LLP web site), here.  Here are a few items I cut and paste to whet readers' interest:

[T]he criminal tax division of the U.S. Department of Justice (DOJ) have now focused attention on three of Israel's biggest banks: Bank Leumi Le-Israel, Bank Hapoalim and Mizrahi-Tefahot Bank, to see if they helped U.S. citizens to evade taxes. 

* * * * 

The IRS is now scrutinizing banks outside of Switzerland, including Liechtenstein, India and other countries. In the case of Israeli banks, American authorities are concerned with the flow of non-compliant money from Switzerland to Israel in recent years. As Swiss banking secrecy faded over the past few years, and the U.S. extracted once-"secret" Swiss account details, many taxpayers transferred assets from Switzerland to Israel to avoid detection by the I.R.S. Now, the IRS has caught up with them.  

* * * * 

Whereas until recently, Swiss bank secrecy laws presented a formidable challenge to the IRS, pursuing undisclosed accounts in Israel will not require nearly as much effort. The tax treaty between the U.S. and Israel enables both countries to "exchange such information as is pertinent to . . . fraud or fiscal evasion in relation to the taxes which are the subject of this Convention." Cooperation between the U.S. and Israel is routine in many matters, tax and otherwise. In addition, the U.S. and Israel currently grant legal assistance to each other in criminal matters via a Mutual Legal Assistance Treaty (MLAT). The MLAT states that the U.S. and Israel "express their understanding that this treaty applies to . . . criminal tax offenses . . . ." It is noteworthy that the treaty provides for the exchange of bank records.