Lessons Learned from Manafort Conviction that Every Taxpayer Should Know

  • Avoid checking the box off “no” on Schedule B in response to the question, “Do you have an interest in or signature authority over a financial account in a foreign country?” when, in fact, you do.
  • Avoid failing to report a foreign account in a later year when you have the obligation to do so despite having filed an FBAR in an earlier year. This reveals that you knew that you had an FBAR-reporting obligation in the later year.
  • Avoid holding an account in such a way as to conceal ownership. For example, is it in the name of a “foreign shell corporation or foreign trust,” or some other entity that would make it difficult for the IRS to learn your true identity as the owner? Is the account a numbered account?
  • Avoid using coded language, such as asking your private banker, “can you download some tunes for us?” or note that your “gas tank [was] running empty” when you required additional cash to be deposited.
  • Avoid filing some tax forms and not others.
  • Avoid keeping two sets of books.
  • Avoid instructing bank personnel to hold back your bank statements and refrain from mailing them to you in the U.S. (if the U.S. residence was listed as your primary residence).

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Michael is an attorney specializing in entertainment law and a professionally-trained actor. He is a partner in the law firm of DeBlis Law.

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Michael DeBlis

Michael DeBlis

Michael is an attorney specializing in entertainment law and a professionally-trained actor. He is a partner in the law firm of DeBlis Law.

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