Woodkirk Stone
The founder of a Russian bank was convicted today of his felony conviction for filing a false tax return. As required by his plea deal, prior to sentencing Oleg Tinkov, aka Oleg Tinkoff, paid $ 508,936,184, more than double what he sought to avoid paying to the US Treasury through a scheme aimed at renouncing his US citizenship and concealing important actions from the IRS. gains he knew should be reported. This includes $ 248,525,339 in taxes, statutory interest on that tax and a fraud penalty of nearly $ 100 million. Tinkov was also fined $ 250,000, which is the maximum allowed by law, and a prison term and one year on probation.
Tinkov was indicted in September 2019 for willfully filing false income tax returns and was arrested on February 26, 2020 in London, United Kingdom (UK). The United States requested extradition and Tinkov contested on medical grounds. In public records, Tinkov revealed he was on a UK-based intensive treatment plan for acute myeloid leukemia and graft-versus-host disease, which left him immunosuppressed and unable to travel safely. security for the foreseeable future.
On October 1, 2021, Tinkov pleaded guilty to filing a false income tax return. According to the plea agreement, Tinkov was born in Russia and became a naturalized US citizen in 1996. From that time until 2013, he filed US tax returns. In late 2005 or 2006, Tinkov founded Tinkoff Credit Services (TCS), a Russian-based branchless bank that provides customers with online financial and banking services. Through a foreign entity, Tinkov indirectly held the majority of TCS shares.
In October 2013, TCS completed an initial public offering (IPO) on the London Stock Exchange and became a multi-billion dollar listed company. As part of its IPO, Tinkov sold a small portion of its controlling stake for over $ 192 million, and its post-IPO assets had a fair market value of over $ 1.1 billion. . Three days after the successful IPO, Tinkov went to the US Embassy in Moscow, Russia to renounce his US citizenship.
As part of his expatriation, Tinkov was required to file an initial and annual expatriation declaration in the United States. This form requires expats with a net worth of $ 2 million or more to report the implicit sale of their worldwide assets to the IRS as if those assets had been sold the day before the expatriation. The taxpayer is then required to declare and pay tax on the gain from such an implied sale.
Tinkov was made aware of his reporting and tax obligations both by the US Embassy in Moscow and his US-based accountant. When asked by his accountant if his net worth exceeded $ 2 million to complete the expatriation form, Tinkov lied and replied that he had no assets over $ 2 million. When his accountant later asked if his net worth was less than $ 2 million, rather than answering the question, Tinkov himself filled out the expatriation form by falsely stating that his net worth was only $ 300,000. On February 26, 2014, Tinkov filed an individual income tax return for 2013 that falsely stated that his income was only $ 205,317. In addition, Tinkov did not report any gain from the implicit sale of his property valued at over $ 1.1 billion, nor did he pay applicable taxes as required by law. . In total, Tinkov caused a tax loss of $ 248,525,339, which he paid in full with substantial penalties and interest as part of his plea, as well as tax liabilities for the remaining years.
Acting Assistant Deputy Attorney General Stuart M. Goldberg, Acting U.S. Attorney Stephanie M. Hinds for the Northern District of California, and Acting Special Agent in Charge Darrell J. Waldon of the IRS Field Office- CI in Washington, DC made the announcement.
The IRS-Criminal Investigations Division investigated the case. The Department of Justice’s international affairs office and law enforcement partners in the UK secured Tinkov’s arrest abroad.
Assistant U.S. Attorneys Michelle J. Kane and Colin Sampson and Former Assistant U.S. Attorney Jose Olivares of the U.S. Attorney’s Office for the Northern District of California and Attorney Peter Anthony and Former Deputy Chief Yael T. Epstein of the Tax Division continued the case.