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LAW OFFICES OF

J . W HITFIELD L ARRABEE
TRIAL AND APPELLATE LAWYERS
251 HARVARD STREET, SUITE 9
BROOKLINE, MASSACHUSETTS 02445

TELEPHONE: (617) 566-3670


FACSIMILE: (617) 507-6435
JW.LARRABEE@VERIZON.NET

August 17, 2016

Internal Revenue Service


Stop 31313
Fresno, CA 93888
Re:

In The Matter Of: Paul John Manafort, Jr., Davis Manafort, Inc., Davis, Manafort and
Freedman, Inc., and, Davis Manafort International LLC

Dear Sir or Madam:


Enclosed please find an Information Referral and Complaint against Paul John Manafort,
Jr., Davis Manafort, Inc., Davis, Manafort and Freedman, Inc., and, Davis Manafort
International LLC together with IRS form 3949-A.
Thank you for your time and consideration of these matters.
Very truly yours,

J. Whitfield Larrabee
JWL/hg
Enclosures

UNITED STATES DEPARTMENT OF THE TREASURY


INTERNAL REVENUE SERVICE

IN THE MATTER OF:


PAUL JOHN MANAFORT, JR.,
DAVIS MANAFORT, INC.,
DAVIS, MANAFORT AND
FREEDMAN, INC., and, DAVIS
MANAFORT INTERNATIONAL LLC
Respondents

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INFORMATION REFERRAL
AND COMPLAINT

INTRODUCTION
1.

This is an information referral and complaint for civil and criminal violations of the
United States Internal Revenue Code related to the failure to report and to pay income
taxes by Paul John Manafort, Jr. (hereinafter Manafort) and various businesses subject
to his ownership and control. The complaint is based on evidence of $12.7 million in
cash payments to Manafort from the Ukraine Party of Regions between 2007 and 2012. It
is also based on evidence that the respondents failed to report these payments as income
and consequently failed to pay income taxes on this unreported income.
PARTIES

2.

Complainant, J. Whitfield Larrabee (hereinafter Larrabee), is a resident of


Massachusetts. Larrabee, a licensed attorney, is admitted to the practice of law in the
Commonwealth of Massachusetts, the United States District Court for Massachusetts, and
the United States First Circuit Court of Appeals.

3.

Respondent Paul John Manafort, Jr. has residences at 10 Saint James Drive, West Palm
Beach, Florida 33418 and 601 North Fairfax Street, #405, Alexandria, VA 22314.
Manafort was a principal in Davis, Manafort and Freedman, Inc. at all times relevant to
this complaint. Manafort was also a principal in Davis Manafort International. Manafort
was a principal of Davis Manafort, Inc. As a citizen and resident of the United States,
Manafort is required to pay federal income taxes.

4.

Davis, Manafort and Freedman, Inc. had a last known address of 211 North Union Street,
Alexandria, Virginia 22314 or 5270 Shawnee Road, Suite 250, Alexandria, Virginia
22312. Davis Manafort International LLC, a Delaware limited liability company, was a
related entity doing business in Ukraine. Davis Manafort, Inc. is a Delaware corporation.
These businesses, each of which were subject to Manaforts ownership and control, were
involved in political consulting, public relations, and allegedly, in racketeering or other
illegal activities. Based on their domicile in the United States, these companies are
required to pay federal income taxes.

STATEMENT OF FACTS
5.

Manafort and the other respondents performed political consulting and other services for
Viktor F. Yanukovych (hereinafter Yanukovych), the former President of Ukraine, for
the Party of Regions, Yanukovychs pro-Russian Ukrainian party, and for their agents and
employees.

6.

Yanukovych held the office of President of Ukraine from February 25, 2010 until
February 22, 2014.

7.

After Yanukovych left office, Ukrainian government investigators working for the
National Anti-Corruption Bureau conducted an investigation of a corrupt network used by
Yanukovych and the Party of Regions to loot Ukrainian assets and influence elections
during Yanukovychs administration.

8.

The Anti-Corruption Bureau of Ukraine obtained secret ledgers, kept by the Party of
Regions, after Yanukovych left office.

9.

The ledgers contain 22 separate references to cash payments made to Manafort by the
Party of Regions between 2007 and 2012. The payments totaled $12.7 million according
to Ukrainian government officials in the Anti-Corruption Bureau and according to copies
of the ledgers provided to the news media.1 Exhibit A, attached hereto.

10.

Manafort has denied receiving the cash payments, stating: The suggestion that I
accepted cash payments is unfounded, silly and nonsensical.2 Exhibit B, attached
hereto. It is unlikely that Manafort, or business entities under his control, reported
income, and paid income taxes, on income that he presently denies receiving.

11.

There is probable cause to establish that Manafort received payments totaling $12.7
million based on the numerous references to different cash payments to him contained in
the ledgers, the lack of any substantial reason to falsely list Manafort in the ledgers at the
time they were seized or before that time, and Manaforts aid and assistance to
Yanukovych and the Party of Nations at times when their criminal activities and
corruption were obvious and widely reported. Yanukovych was allied with and supported
by the notoriously corrupt leader of Russia, Vladimir Putin.

Andrew E. Kramer, Mike Mcintire and Barry Meier, Secret Ledger in Ukraine Lists
Cash for Donald Trumps Campaign Chief, New York Times, August 14, 2016
http://www.nytimes.com/2016/08/15/us/politics/paul-manafort-ukraine-donald-trump.html?_r=0
2

Alan Rappeport, Trump Campaign and Its Chief, Paul Manafort, Try to Move Past
Ukraine Report, New York Times, AUG. 15, 2016,
http://www.nytimes.com/2016/08/16/us/politics/trump-campaign-paul-manafort-ukraine-cash-pa
yments-russia.html
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12.

Taras V. Chornovil, a former leader in the Party of Regions, has confirmed that the Party
of Regions headquarters held two safes stuffed with $100 bills, and that cash was used for
off-the-books activity. Exhibit A. Chornovils report, based on his personal
knowledge and observations, is further evidence that establishes probable cause that
Manafort had unreported and hidden income related to his activities in Ukraine.

13.

On November 19, 2009, The Kiev Post published an article reporting that Manaforts
company, in filings with the United States Department of Justice, reported receiving
$63,750 from the Party of Regions in the six month period ending in March 31, 2008.
The article provides confirmation that Manafort received income from the Party of
Regions, and contributes to the determination that there is probable cause to conclude that
Manafort and his companies under-reported the amount of money received from the Party
of Regions in their federal tax returns.3 Exhibit C, attached hereto.

14.

Manafort, his companies, partners and business associates have experience in the use of
shell companies, whose owners are shielded by secrecy laws, in jurisdictions that aid
individuals in concealing assets and income. These jurisdictions include, but are not
limited to, British Virgin Islands, Belize, the Seychelles and the Cayman Islands. Based
on his experience and education as a lawyer, Manafort is knowledgeable in how to
establish and use foreign and domestic shell corporations to hide money and evade paying
taxes. Exhibit A, and, Winding Up Petition, In The Matter of Section 36(3) of the
Exempted Limited Partnership Law, 2014, And In The Matter of Pericles Emerging
Market Partners, L.P., Grand Court of the Cayman Islands, Cause No. 0131 of 2014,
attached hereto as Exhibit D.

15.

Based on his knowledge, training, experience, motive and opportunity, it is likely that
Manafort has taken steps to hide or attempt to hide $12.7 million in payments made to
him by the Party of Regions.

Alina Pastukhova and Kateryna Grushenko, Paid advisers descend on candidates,


nation, Kyiv Post, November 19, 2009
https://web.archive.org/web/20091124072239/http://www.kyivpost.com/news/politics/detail/532
51/
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COUNT 1
FAILURE TO REPORT INCOME AND
FAILURE TO PAY TAX FOR TAX YEARS 2007 TO 2012
16.

The allegations in the preceding paragraphs are incorporated by reference as if fully set
forth herein.

17.

There is probable cause to establish that Manafort and the business entities set forth in
this complaint have engaged in tax evasion by failure to report income on their tax returns
and by failure to pay income tax in violation of the United States Internal Revenue Code,
7201, 7202 and 7203.

18.

There is probable cause to establish that Manafort, his business associates and the
business entities set forth in this complaint have engaged in a civil and criminal
conspiracy to evade paying income taxes by conspiring and agreeing to not report income
on their tax returns and by conspiring and agreeing not to pay income tax in violation of
the United States Internal Revenue Code, 7201, 7202 and 7203.
WHEREFORE, the complainant demands:
A.

that the Internal Revenue Service initiate an investigation of the respondents and
conduct appropriate audits of the respondents for the tax years 2007 through 2012.

B.

That the Internal Revenue Service make a referral to the United States Department
of Justice recommending an investigation and criminal prosecution of the
respondents for tax evasion.
Respectfully submitted,

J. Whitfield Larrabee
Law Office of J. Whitfield Larrabee
251 Harvard Street, Suite 9
Brookline, MA 02446
jwlarrabee@verizon.net
(617) 566-3670
BBO # 553499

CERTIFICATE OF SERVICE AND FILING


I, J. Whitfield Larrabee, hereby certify that on August 17, 2016, I filed this complaint by
mailing a copy of the complaint together with IRS Form 3949-A to Internal Revenue Service,
Stop 31313, Fresno, California 93888.

J. Whitfield Larrabee