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Case 1:17-cr-00201-ABJ    Document 190-1    Filed 02/22/18    Page 8 of 37

13. The Internal Revenue Service (IRS) was a bureau in the Treasury responsible for administering the tax laws of the United States and collecting taxes owed to the Treasury.

The Tax Scheme

MANAFORT And GATES’ Wiring Money From Offshore Accounts Into The United States

14. In order to use the money in the offshore nominee accounts of the MANAFORT–GATES entities without paying taxes on it, MANAFORT and GATES caused millions of dollars in wire transfers from these accounts to be made for goods, services, and real estate. They did not report these transfers as income.

15. From 2008 to 2014, MANAFORT caused the following wires, totaling over $12,000,000, to be sent to the vendors listed below for personal items. MANAFORT did not pay taxes on this income, which was used to make the purchases.

Payee Transaction Date Originating Account Holder Country of Origination Amount of Transaction
Vendor A (Home Improvement Company in the Hamptons, New York) 6/10/2008 LOAV Advisors Limited Cyprus $107,000
6/25/2008 LOAV Advisors Limited Cyprus $23,500
7/7/2008 LOAV Advisors Limited Cyprus $20,000
8/5/2008 Yiakora Ventures Limited Cyprus $59,000
9/2/2008 Yiakora Ventures Limited Cyprus $272,000
10/6/2008 Yiakora Ventures Limited Cyprus $109,000
10/24/2008 Yiakora Ventures Limited Cyprus $107,800
11/20/2008 Yiakora Ventures Limited Cyprus $77,400
12/22/2008 Yiakora Ventures Limited Cyprus $100,000
1/14/2009 Yiakora Ventures Limited Cyprus $9,250
1/29/2009 Yiakora Ventures Limited Cyprus $97,670
2/25/2009 Yiakora Ventures Limited Cyprus $108,100
4/16/2009 Yiakora Ventures Limited Cyprus $94,394
5/7/2009 Yiakora Ventures Limited Cyprus $54,000
5/12/2009 Yiakora Ventures Limited Cyprus $9,550
6/1/2009 Yiakora Ventures Limited Cyprus $86,650
6/18/2009 Yiakora Ventures Limited Cyprus $34,400
7/31/2009 Yiakora Ventures Limited Cyprus $106,000

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