The IRS Criminal Investigation Division announced what is being called the largest tax charge ever against an individual in the United States.

Robert T. Brockman, a 79 year old resident of Texas and the chairman and CEO of The Reynolds Company, has been accused of hiding over $2 billion in income from the IRS over 20 years.

Brockman was charged in a 39-count indictment that focuses on two separate pieces:

The first set of charges focus on tax fraud, including tax evasion and failure to file Reports of Foreign Bank and Financial Accounts (FBAR) for the years 2000 through 2018.

The second set of charges is an investor fraud scheme involving manipulating debt securities.

Brockman is accused of directing untaxed income to secret bank accounts in Bermuda and Switzerland.

The take-away lesson for restaurant owners is this:  The FBAR rules apply to anyone who has, at any point during the tax year, more than $10,000 (in American dollars) in a foreign bank account or other foreign financial account.  If Kallas prepares your personal tax return, we need to know this to file the proper forms.  There is no tax to pay but there are severe penalties for not reporting properly.