IRS asks Swiss for help probing $100B in tax evasion

•The Lowy family largely controls the Westfield Group, the self-described "world's largest listed retail property group by equity market capitalization." Frank Lowy, an Australian citizen the report said was once forced to pay a large settlement to that country's tax authorities, is the company's main shareholder and chairman. Three sons hold Westfield positions, including Peter Lowy, an American citizen who heads the firm's U.S. operations.

According to the Senate report, the Lowys had several offshore entities, including the Luperla Foundation, an LGT-created vehicle that in 2001 held about $68 million in assets. A Delaware corporation called Beverly Park was given authority to name Luperla's beneficiaries.

LGT records examined by Senate investigators showed the Frank Lowy Family Trust controlled Beverly Park through three other entities. Moreover, Beverly Park's address was the Westfield Group's U.S. headquarters in California.

IRS investigators contacted the Lowys about Beverly Park last year as part of an ongoing investigation, the subcommittee reported. Family members and Beverly Park officers told the IRS the corporation had no ties to any foreign entities, the Senate report said.

Although the subcommittee listed Peter Lowy as a witness for today's hearing, he is not expected to testify.

"The Lowy family has done nothing improper," said Robert Bennett, a Washington lawyer who represents them. "We have not yet had the chance to thoroughly review the report, but any process that results in a report being issued before the subjects of the report have any meaningful opportunity to respond is grossly unfair, deeply flawed and unreliable."

•Harvey Greenfield and his son, Steven, are New York-based businessmen in the toy industry. Harvey Greenfield is CEO of Commonwealth Toy and Novelty, an international manufacturer of stuffed animals and dolls with offices in New York, Holland, Taiwan and Hong Kong. Steven Greenfield is the former president of the company, which has $35 million in annual sales, according to an Experian Business Report estimate.

According to the Senate panel, the Greenfields control the Maverick Foundation, an LGT-created entity that in 2001 held assets of roughly $2.2 million.

Internal LGT records obtained by the subcommittee show the Greenfields attended a March 2001 meeting with bank officials, including the brother of Liechtenstein's reigning prince, after a separate bank in Bermuda decided to end its own business with the family.

"The client is now on the search for a safe haven for his offshore assets," stated an LGT memo, which also said the Greenfields wanted to end ties with the Bermuda bank with "as few traces as possible."

LGT officials pitched the Greenfields about transferring $30 million to the Liechtenstein bank. It is unclear whether the transaction ever took place. But the Senate report said an attorney for the Greenfields told subcommittee investigators the family is negotiating with the IRS "over tax liability issues related to Liechtenstein."

The Greenfields did not respond to telephone messages left by USA TODAY.

•Until his death in 2006, James Albright Marsh was a successful construction contractor who lived in Florida with his six children. So successful that LGT helped him create four Liechtenstein foundations that by 2007 held assets "with a combined value of more than $49 million," the Senate panel reported.

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