(Bloomberg) — The billionaire facing the largest-ever U.S. tax-evasion case against a man is urging a judge to accept his family trust’s proposal to pay $1.45 on his property and assets in exchange for the IRS. Billion discount.
Robert Brockman’s offshore charitable trust is set to move money from Switzerland to US accounts, according to a filing Friday by his lawyers in federal court in Houston. In return, Brockman wants the Internal Revenue Service to lift its so-called threat assessment, which is imposed on taxpayers the agency fears may leave the country or fail to pay their bills.
That valuation has led the IRS to sixteen funds from accounts owned by Brockman and his wife, placed liens on their former home and other properties, and attached their retirement pay from Reynolds & Reynolds, the auto dealership software company Brockman owned. has made.
“It is unfair to deprive Mr. Brockman of his retirement pay, or to prevent Mrs. Brockman from selling a residence to Brockman a year ago, as the IRS is currently doing,” Brockman’s lawyers said Friday. said in the filing.
Brockman’s filing was part of his effort to order the appraisal to be removed from the court. A Justice Department spokesman declined to comment.
Brockman is facing criminal charges that he evaded taxes and laundered money on $2 billion in income, as well as parallel civil claims. He has pleaded not guilty, but has also claimed that he is not competent to stand trial because of the dementia. Prosecutors say he is a fake. A judge hearing Brockman’s competence in November did not deliver a ruling.
The indictment alleges that Brockman controlled the Bermuda-based family trust and its billions of dollars in assets. His lawyers say Brockman has no role in the management of the trust, which indirectly owns Reynolds and Reynolds, and cites Bermuda court decisions supporting the independence of the trust.
$100 million dividend
An attorney for the trust, Marc Serere, outlining the proposal in a March 15 letter, said that the prosecution and threat assessment created “a great deal of uncertainty” about Reynolds & Reynolds’ “substantial shareholding” to be worth $$ is more than 5 billion. ,
Srire said the trust will transfer the $1.35 billion held in US Treasury bills held in Switzerland’s Bank Mirabaud to one or more financial institutions in the US.
Following Brockman’s indictment in October 2020, Swiss prosecutors froze about $950 million linked to Brockman. It was not immediately clear how this would affect the proposal.
Brockman’s lawyers said Friday that the government “cannot be both ways: it cannot simultaneously argue that it owns a multi-billion dollar asset that is located in the United States, and simultaneously The argument is strong that its ability to collect is at risk.”
The case Brockman v. United States, 22-cv-202, US District Court, Southern District of Texas (Houston).