Deutsche Bank is being sued for $190m for alleged tax fraud activities from 14 years ago.
According to a legal complaint filed in the US District Court in Manhattan, the amount that the government is trying to recover for the German lender includes alleged unpaid taxes, penalties and interest.
"Through fraudulent conveyances involving shell companies, Deutsche Bank tried to make its potential tax liabilities disappear," said US Attorney Preet Bharara in a statement.
"This was nothing more than a shell game."
The US government alleges that Deutsche Bank used "insolvent" shell companies to hide profits from the country's Internal Revenue Service which therefore is an act of fraud.
Bharara, representing the government, claimed that an example of this came to light when Deutsche Bank bought drug maker Bristol-Myers Squibb Co in 1999 for an unrealised $150m gain in shares, but "sold" the stock for below fair value to said shell companies.
Deutsche Bank therefore avoided $51m tax bill from the US after triggering a tax liability clause by selling the shares through the shell companies to another entity owned by the German lender.
This led to Deutsche Bank only repaying the short term loans that the shell companies used to fund the share purchase, without paying tax.
Deutsche Bank said in a statement that the German lender "fully addressed" the matter in a 2009 agreement with the IRS.
The bank added that the government had "abandoned" the theory that the bank was liable for the taxes.
"While it is not clear to us why we are being pursued again for the same taxes, we plan to again defend vigorously against these claims," a spokesperson added.
The case is U.S. v Deutsche Bank AG et al, U.S. District Court, Southern District of New York, No. 14-09669.