IRS Obtains Data from Spanish Bank for Spanish Tax Authority

In Rabassa v. United States (11th Cir. Apr. 23, 2024), affirming the Southern District of Florida (2023), the Spanish tax administration (“Agencia Tributaria”) apparently found itself unable, as a practical matter, to obtain, from the Spanish home office of Banco de Sabadell, the fourth largest Spanish bank, information concerning bank accounts in the unincorporated, Florida-licensed, Miami branch of Banco de Sabadell. Agencia Tributaria apparently believed the accounts were owned by a Spanish corporation controlled by an individual whom the authorities believed was a Spanish tax resident.

According to an IRS affidavit, Agencia Tributaria’s exchange of information request to the IRS, ...