I'm curious about how the statute of limitations will apply. Much of the indictment refers to alleged crimes happening many years ago.
It appears the statute of limitations for tax fraud is 6 years. nope.. its much longer
https://wiggamlaw.com/blog/irs-10-year-back-taxes-statute-of-limitations/
Quote
Can the IRS Take More Than 10 Years to Collect Tax Debts?
In some cases, the IRS can take more than 10 years to collect tax debts. This happens when an event causes the clock to stop ticking on the statute of limitations and the deadline gets extended. This is called tolling the statute of limitations.
To give you an example, imagine that you have five years left until the statute of limitations expires. Then, you take an action that pauses the clock for two months. At the end of those two months, you still have five years left on the statute of limitations. If the clock had not stopped, you would only have four years and 10 months left.
Tolling the Statute of Limitations
Here are actions that toll the collection statute:
Applying for an offer in compromise — This tolls the statute from the day you apply to the 30 days after the IRS rejects the offer.
Requesting an installment agreement — When you apply for a payment plan, the statute is tolled while your application is pending.
Filing an innocent spouse claim — The statute tolls on the day you apply, and then it restarts at a range of different times depending on the situation. It only tolls the statute for the spouse who applies. It doesn’t affect the CSED for the other spouse.
Filing bankruptcy — This tolls the statute during the bankruptcy case and for six months afterward.
Filing a Taxpayer Assistance Order — The statute is tolled from the day you file the assistance order until the Taxpayer Advocate issues a decision on your request.
Appealing a collection action through a collection due process hearing — The clock stops from the time you appeal until 90 days after you receive a decision from appeals.
Leaving the country for six or more months in a row — In this case, the statute does not expire until at least six months after you get back to the United States.
In some cases, the IRS can take more than 10 years to collect tax debts. This happens when an event causes the clock to stop ticking on the statute of limitations and the deadline gets extended. This is called tolling the statute of limitations.
To give you an example, imagine that you have five years left until the statute of limitations expires. Then, you take an action that pauses the clock for two months. At the end of those two months, you still have five years left on the statute of limitations. If the clock had not stopped, you would only have four years and 10 months left.
Tolling the Statute of Limitations
Here are actions that toll the collection statute:
Applying for an offer in compromise — This tolls the statute from the day you apply to the 30 days after the IRS rejects the offer.
Requesting an installment agreement — When you apply for a payment plan, the statute is tolled while your application is pending.
Filing an innocent spouse claim — The statute tolls on the day you apply, and then it restarts at a range of different times depending on the situation. It only tolls the statute for the spouse who applies. It doesn’t affect the CSED for the other spouse.
Filing bankruptcy — This tolls the statute during the bankruptcy case and for six months afterward.
Filing a Taxpayer Assistance Order — The statute is tolled from the day you file the assistance order until the Taxpayer Advocate issues a decision on your request.
Appealing a collection action through a collection due process hearing — The clock stops from the time you appeal until 90 days after you receive a decision from appeals.
Leaving the country for six or more months in a row — In this case, the statute does not expire until at least six months after you get back to the United States.
in short being an expat in another country means the clock stops when you left. but when you return they can start the clock again. so even if you left the country in 2014 and returned in say 2022.. the deadline of a 2014 case only starts its first year in 2022
