Streamlined Disclosure in U.S. v. Brian Nelson Booker: A Former CPA Sets a Dubious Precedent

Abstract

Brian Nelson Booker has the dubious distinction of being the first person criminally charged by the Department of Justice (DOJ) with allegedly making false statements in connection with the IRS’s Streamlined Domestic Offshore Program (SDOP). The former CPA is now a fugitive, living since 2016 in a country that has no extradition treaty with the United States. The allegations in the Booker indictment [U.S. v. Brian Nelson Booker, 19 Cr. 60152 (S.D. Fla.)] should alarm anyone who has participated in the submission of a false streamlined disclosure, and it is an unfortunate reminder of the need for tax advisors to be vigilant when making assertions of non willfulness before the IRS.

Keywords: Streamlined Disclosure, U.S. v. Brian Nelson Booker