Category: International Business

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Robert F. Smith

Background and Non-Prosecution Agreement

INTRODUCTION:

Mr. Smith in 2020, at the age of 57, entered into a Non-Prosecution Agreement, NPA, with the IRS.   Let’s look at what I believe happened to Mr. Smith to cause his personal and professional life to intersect with potential Criminal Prosecution with the United States Government.  Let’s also see what could have been done differently to head off such a horrible outcome to his reputation, his freedom, and a lifelong stain on his legacy.

Finally, let’s see if this is now the end of Mr. Smith’s criminal and civil problems with the successful negotiation of this NPA.

PART I.

Background

On February 3, 2017, U.S. Magistrate Judge Thomas Rueter ruled that Google must provide emails stored overseas to the FBI for their domestic fraud investigation, despite an earlier decision finding no such obligation for Microsoft. The ruling was made in Philadelphia that transferring emails from a
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11.5 Million Documents Leaked: The Crippling Panama Papers Transmuted Overnight From Privileged Attorney Information To Forever In The Hands of the Public And The Feared U.S. Treasury.

As you the Reader must suspect or know by now, this epic leak has attracted all the wrong attention and interest of governmental revenue departments around the world. The U.S. Treasury has made their intentions very clear, where its citizens are found to have been a part of tax evasion, the financial penalties will be destructive on one’s financial security of lifelong wealth accumulations. Although the investigations from these leaked documents will begin quietly and without any fanfare, a simple one page letter from the Large Audit and International Division will be just the beginning of a long