A New York judge set two million dollars' (£1.2 million) bail and home detention with electronic monitoring for a British lawyer accused of advising the family of a former Fidelity Investments executive how to dodge US taxes by hiding millions overseas.
Michael Little, 61, of Hampshire, England, was expected to remain in custody overnight after a US magistrate judge in Manhattan ordered bail secured by at least one million dollars in cash or property on the charge of conspiracy to commit tax fraud.
German-born Little, who has a home in Long Island City, was arrested on Thursday night as he arrived at Kennedy International Airport on a flight from London, where he lives with his wife and children.
Assistant US Attorney Stanley Okula said Little engaged in a decade-long tax evasion scheme in which he counselled the family of the late Harry Seggerman how to hide at least 10 million dollars (£6.2 million) overseas. Mr Seggerman, who died in May 2001, retired as a vice chairman of Fidelity in 1992.
In court papers, the US government said Little met Mr Seggerman's beneficiaries and descendants at a Manhattan hotel in August 2001 and told them that the patriarch had left them about 10 million dollars of a 20 million-plus estate in overseas accounts that had never been declared to US tax authorities.
The government said Little defrauded the Internal Revenue Service by telling family members how to continue hiding those assets by establishing Swiss bank accounts that would be nominally owned or controlled by Little and a Swiss lawyer.
It said he also advised them that they could bring money back to the United States in "little chunks" through traveller's cheques or by disguising money transfers to the United States as being related to the sales of artwork or jewellery.
The government said he transferred some of the money from Switzerland to London, where Seggerman family members could pick up funds during trips there and bring all or part of the money back to the United States as cash, generally in amounts less than 10,000 dollars.
To hide communications, members of the Seggerman family used codewords in which "small" was used to refer to Michael Little, "beef" meant money, "lbs" meant 1,000 dollars and "FDA" referenced the IRS, the government said.
Suzanne Seggerman pleaded guilty in December 2010 to conspiring to defraud US tax authorities and subscribing to false individual tax returns. Her lawyer, Russell Gioiella, said his client "fully co-operated with the government investigation into the overseas accounts left to the family by her father".