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Part II.


As discussed in Part I. of this continuing Article, Denmark is vigorously looking for the 6 individuals who have allegedly defrauded the Government of Denmark of more than $2.1 billion via a dividend-tax scam.  Three of the 6 individuals are US citizens and as the year-long investigation continues, more individuals and entities will be named.  

The German lender, North Channel Bank, is now added to the list of those committing economic malfeasance and 3 of the above-mentioned individuals were/are owners of North Channel Bank.  Denmark continues to name their mastermind behind this scheme as the hedge fund founder, Sanjay Shah.  Additional parties to be charged will be almost globally with an ever-increasing network of bankers, lawyers, and other financiers.  Prosecutors now disclose that a series of offshore pension plans were created to claim refunds on dividend taxes, despite never having owned the underlying Danish shares.


In Part I., we discussed Denmark may use its option to physically bring the individuals to Denmark via its extradition agreements with other countries.

Currently, there are 6 individuals and the North Channel Bank.  No doubt that many others will be added to this list of individuals for extradition since hundreds of fictitious share trades were made between 27 U.S.-based one-person pension plans, nine companies, and intermediaries to make it appear as if the pension plans were entitled to tax refunds.

By Michael B. Nelson, Esq.

April 16, 2021

Michael Nelson

Michael has great depth of experiences and skills that evolved from over 35 years of representing international businesses, executives, expatriates and multi-national families. From these years of successful legal representations of CEOs of Fortune 500 Companies to family clients with needs from complex estate planning to international trusts and private foundations. He is committed to his clients, always finding better alternatives or options for his clients. Dedication to the client is synonymous with his name.