The Tax Times: Paul Manafort, Donald Trump’s Campaign Manager, Allegedly Owes $3M In FBAR Penalties

Friday, April 29, 2022

Paul Manafort, Donald Trump’s Campaign Manager, Allegedly Owes $3M In FBAR Penalties

A prosecutor has asked a South Florida federal judge to order Paul Manafort, Donald Trump’s presidential campaign manager in 2016, to pay nearly $3 million in fees to the U.S. government over his failure to disclose foreign income hidden in over two dozen shell corporations and foreign accounts in 2013 and 2014, according to a federal lawsuit.

In court papers filed on April 28, 2022, Deputy Assistant Attorney General David Hubbert said that Manafort had to pay $2,976,350.15 due to his “willful failure to timely report his financial interest in foreign bank accounts.”

Manafort was hit with the penalties after he didn't report his interest in a number of foreign companies and accounts in 2013 and 2014. Specifically, he didn't report that on his federal income tax returns or through a Report of Foreign Bank and Financial Accounts, or FBAR, for the years 2013 and 2014, prosecutors said.

"Manafort was required to file an FBAR reporting his interests in the accounts no later than June 30, 2014," prosecutors said in the suit. "Manafort was also required to report his interests in the accounts on Schedule B to his 2013 federal individual income tax return."

"Manfort has never filed an FBAR reporting his interest in foreign accounts for 2013," they added.

And the same goes for his interests during 2014, according to the government.

Specifically, Prosecutors Said Manfort Had
A Financial Interest In At Least 18 Accounts In Cyprus,
One Account In The United Kingdom And
Three Accounts In St. Vincent And The Grenadines In 2013.

And In 2014, He Had A Financial Interest In
The St. Vincent And Grenadines Accounts, They Said.

The U.S. Treasury Secretary assessed the penalties against Manafort in 2020, the government said. Despite the notices and demands for payment, Manafort hasn't paid up, it said.

The government pointed to a pair of high-profile criminal cases involving Manafort. Both garnered convictions: one in Washington, D.C., for obstructing the Russia investigation conducted by special counsel Robert Mueller and unsanctioned lobbying work, and another in Virginia for bank and tax fraud.

However, things began looking up for Manafort in May 2020, when he was moved from prison to home confinement due to COVID-19 concerns. Then former President Donald Trump pardoned Manafort for his federal crimes in December of that year.

Most recently, New York's highest court declined to take up the Manhattan district attorney's appeal of the dismissal of additional state fraud charges against Manafort, after two lower courts agreed the indictment should be dismissed on double jeopardy grounds.

In Thursday's complaint, the government focused on Manafort's guilty plea entered in the District of Columbia case. As part of that plea, Manafort agreed that a statement of offenses and other acts "fairly and accurately described his actions and involvement," prosecutors said. That statement detailed his "willful failure to comply with the FBAR filing requirements for several years, including 2013 and 2014," they said.

The complaint included an excerpt from the statement reading, in part, "From 2008 through 2014, Manafort caused millions of dollars of wire transfers to be made from offshore nominee accounts, without paying taxes on that income."

Prosecutors asked the court to enter judgment against Manafort for his failure to pay and award it interest and additional penalties.

Jeffrey A. Neiman, who's representing Manafort in the case, said in a statement Thursday that the suit "seeks a money judgment against Mr. Manafort for simply failing to file a tax form."

"Mr. Manafort was aware the government was going to file the suit because he has tried for months to resolve this civil matter," Neiman said. "Nonetheless, the government insisted on filing this suit simply to embarrass Mr. Manafort."

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