Who knew tax evasion was super criminal? Ask Oleg Tinkov, Founder of Russian Bank Pleads Guilty to Tax Fraud..

Admits to Concealing More Than $1 Billion in Assets when Renouncing U.S. Citizenship and Agrees to Pay More Than $500 Million Penalty

Is $1.1 Billion in Tax Evasion bad?

I mean who knew that engaging in intentional tax evasion was a crime? I mean I figured that most average adults actually file and pay their taxes versus pretending to be a patriot but I know for a fact a certain charlatan hasn’t file their taxes in years. Oh wait - I digress

Oleg Tinkov - Indictment and Plea Agreement

In September of 2019 a Federal Grand Jury in the Central District of California handed down an indictment (see CDCA-ECF) -charging Oleg Tinkov with violating; 26 U.S.C. § 7206(1) - Making and Subscribing A False Tax Return, Statement, and Document (Two Counts) - this indictment remained under seal until March 2020 when the DOJ moved to unseal Defendant TINKOV indictment

• Oleg Tinkov was the indirect majority shareholder of a branchless online bank that provided its customers with financial and bank services. 

• …as a result of an initial public offering (IPO) on the London Stock Exchange in 2013

• Tinkov beneficially owned more than $1 billion worth of the bank’s shares.

• …three days after the IPO, Tinkov renounced his U.S. citizenship, he became a naturalized citizen in 1996 - according to USCIS records

  • a taxable event required Tinkov to report to the IRS the constructive sale of his worldwide assets,

  • report the gain on the constructive sale of those assets to the IRS, and pay tax on such gain to the IRS.

• Tinkov allegedly beneficially owned more than $1 billion of TCS shares at the time of his expatriation through a British Virgin Island structure, the indictment charges that Tinkov filed a false 2013 tax return with the IRS that reported income of less than $206,000, and a false 2013 Initial and Annual Expatriation Statement reporting that his net worth was $300,000.m

Companies owned by the Defendant:

• Tinkoff Credit Systems Group Holding PEG was the holding company for Tinkoff Credit Systems

Defendant Tinkoff was the sole beneficiary of these entities. He went on to sell part of his majority shareholder stake in TCS. Which sold for more than $192 million, and his assets following the initial public offering were estimated at more than $1.1 billion…

• April 5, 2013, TINKOV became the 100% shareholder of Beckett Group Ltd., a BVI entity.

• May 28, 2013, Beckett Group Ltd. became the 100% shareholder of twoother BVI entities: (1) Tadek Holding & Finance S.A. ("Tadek Holding"), and (2) Tasos Invest & Finance Inc. ("Tasos Invest").

Prior to TCS IPO - specifically on October 25, 2013, more than 93 million TCS shares were held in the name of Tadek Holding, and more than 10 million TCS shares were held in the name of Tasos Invest. In total, these shares comprised more than 60% of all TCS's shares.

Defendant Tinkov was arrested in the U.K. and was actively fighting extradition. He reason was medical in nature and largely due to his purported leukemia diagnosis and a mere 24 hours after his indictment was unsealed Defendant Tinkov stated he was diagnosed with leukemia —then in February 2021 Barron’s Reported that Defendant Tinkov would devote the rest of his life working for charities. Also in December of 2020 Defendant Tinkov announced he would put $200 million towards his leukemia fund.

Justice Department @TheJusticeDept

Founder of Russian Bank Pleads Guilty to Tax Fraud

justice.govFounder of Russian Bank Pleads Guilty to Tax FraudThe founder of a Russian bank pleaded guilty today to filing a materially false tax return.

What’s curious is his plea agreement in PACER is unavailable or I need to access ECF via a terminal. Realistically that’s not going to happen until early November because during October I’m working remotely from the beach… Notwithstanding, I do strive to be factual and I genuinely enjoy doing legal research. Moreover I have access to certain legal research tools at my disposal. So imagine my surprise when I did a deeper LN and WL search to find the plea agreement in question was originally drafted in May 2020 DOJ-Defendant TINKOV Plea Agreement

If you look at page 10 of the embedded plea agreement it was formally executed - signed by the defendant and the DOJ on September 2, 2021

I lied and told him I did not have assets above $2 million.

I mean as far as candor in a plea agreement, the sub-paragraphs 2a thru 2k are kind of remarkable because it appears the Defendant might actually be remorseful…

On November 11, 2013, my accountant asked me if my net worth was more than $2 million. He also told me that if my net worth was more than $2 million, I would need to provide on Form 8854 information about my assets. I lied and told him I did not have assets above $2 million.

I falsely reported my net worth to be $300,000, even though my ownership in Beckett had a fair market value of more than $1.1 billion...

Restitution $448,957,108.00

…written declaration that I signed under the penalties of perjury even though I did not believe it to be true and correct as to every material matter. That Form falsely reported that my net worth was $300,000 and failed to report other information related to my assets, when I knew that my net worth was substantially more than that and that I was required to report other information related to my assets as described above. I willfully signed and filed that return knowing it was false.

The Defendant is currently in the United Kingdom -where it was previously reported he was proactively fighting extradition… Waves hiya MLAT ¹

..contesting extradition on the charges in the captioned Indictment on the basis that I am undergoing intensive medical treatment for significant health issues which render me immunocompromised. I understand that the government agrees to my request to proceed remotely from the United Kingdom as described in paragraph

In the event I violate any of the terms of the Agreement, I agree that the facts set forth in Paragraph 2 of this Agreement and, if applicable, the fact that I made a sworn admission to them in a previous court proceeding, shall be admissible against me in any subsequent proceeding, including at trial. In any subsequent proceeding conducted after I violate any of the terms of the Agreement, I m and, if applicable, the fact that I made a sworn admission to them at a previous court proceeding.

I agree to pay no less than $506,828,377.00…

I agree to sign closing agreements with the Internal Revenue Service permitting the Internal Revenue Service to assess and collect the total sum of no less than $506,828,377, which includes the 2013 tax liability, the civil fraud penalty and statutory interest on that tax liability, amounting to $448,957,108, plus interest from August 31, 2021 through the date of payment, as well as tax liabilities for other years that I acknowledge that I owe. I agree to pay no less than $506,828,377 in full pursuant to the closing agreements before the time of sentencing. I agree that the government may

And as I previously noted, the footer on the plea agreement shows a May 2020 date but as you can see on pages 9 and 10 the plea agreement was signed by Defendant TINKOV and the DOJ in early September 2021

And with that I actually believe you have the full set of facts - also see footnotes ² for Open Source Link to his indictment and his plea agreement. Now if you’ll excuse me, I have a hot date with a moonlight swim in the ocean and then on to the hot tub - no s’mores because apparently my Amazon Prime grocery order is delayed and I’m not going to drive 45+miles for marshmallows… I have my limits on what I’ll do to make my little happy…

1. USA and U.K. ‘in force” MLAT - https://www.state.gov/wp-content/uploads/2019/02/10-201.49-United-Kingdom-EU-Mutual-Legal-Assistance-Treaty.pdf - last accesses October 1, 2021

• Entered into force February 1, 2010.

• With annex and exchange of notes.

2. USA v Tinkov Plea Agreement via ECF https://ecf.cand.uscourts.gov/doc1/035021123564

Or via my Scribd Account - https://www.scribd.com/document/529078733/USA-v-TINKOV-Sept-2021-Plea-Agreement

2019 CDCA Indictment - https://www.scribd.com/document/529072118/USA-v-Tinkov-Sept-2019-Indictment