International tax advisor sentenced to 30 months for tax fraud scheme

 

Date: Feb. 14, 2025

Contact: newsroom@ci.irs.gov

NEW YORK — Frank Butselaar, of Naarden, Netherlands, was sentenced Feb. 13, 2025, to 30 months imprisonment for aiding or assisting the filing of a false or fraudulent tax return. This follows a guilty plea that was entered Nov. 14, 2024, in the Southern District of New York after seven days of trial testimony demonstrating a sophisticated scheme to shelter income offshore on behalf of ultra-high net worth individuals. In addition to the sentence, Butselaar was ordered to pay restitution of nearly $15.5 million.

As alleged by the Government, and based on the testimony and exhibits received at trial, filings in Court, and statements made in Court: Butselaar advised the creation of offshore structures for multiple ultra-high-net worth individuals who earned money all over the world and did so while a shareholder in the Amsterdam Office of a major U.S.-based international law firm. Those clients included world-famous DJs, including Tijs Verwest, a.k.a. “DJ Tiesto,” and Nick van de Wall, a.k.a. “DJ Afrojack”, fashion models Patricia van der Vliet and Daria Strokous ("referred to collectively as the "Clients").

Butselaar worked with partners at a U.S.-based management firm to file U.S. tax returns for the Clients("Management Firm 1"). When the Clients were becoming or had become U.S. tax residents, the defendant, and his co-conspirators - partners at Management Firm 1 - sought to conceal the Clients’ offshore income through the use of nominee owners of their offshore structures. As part of the scheme, these nominees were installed to make it appear as though the Clients’ earnings now belonged to someone else, generally a family member who lived outside the U.S. Despite these paper changes in ownership, Butselaar and his co-conspirators never told the Clients anything of substance had changed. The Clients—with the knowledge of Butselaar and his co-conspirators at Management Firm-1—continued to operate their offshore entities as their own and believed they had access to and could direct the money they were accumulating offshore.

Between 2012 and 2017, when Verwest was a U.S. Resident taxpayer, Butselaar and co-conspirators, omitted from Verwest’s taxes substantial sums held offshore. Similarly, in 2013, when van de Wall was a U.S. Resident taxpayer, Butselaar and co-conspirators, omitted from van de Wall’s taxes substantial sums held offshore. The amount of unreported income for these two taxpayers exceeded $70 million. During his allocution, Butselaar admitted that partners at Management Firm-1 knowingly omitted overseas income, which should have been reported, from van de Wall’s 2013 U.S. resident return.

While the scheme was operating, Butselaar was repeatedly warned that the income being collected offshore for his Clients was reportable. In fact, six different professionals—CPAs and tax lawyers in the U.S.—told Butselaar that the offshore income being accumulated outside the U.S. for the Clients was reportable in the U.S. In the face of these repeated warnings, Butselaar lied and concealed information from these professionals. Instead, Butselaar worked with his co-conspirators, partners at Management Firm-1, to conceal otherwise reportable income from U.S. authorities. Butselaar pled guilty to one count of aiding or assisting in the filing a fraudulent tax return for the 2013 Tax Year for taxpayer Nick van de Wall, a.k.a. “Afrojack”.

IRS Criminal Investigation (IRS-CI) New York Field Office’s J5 group worked this case. The Joint Chiefs of Global Tax Enforcement is a global partnership that works together to gather information, share intelligence, and conduct coordinated operations against transnational financial crimes. The J5 includes the Australian Taxation Office, the Canada Revenue Agency, the Dutch Fiscal Intelligence and Investigation Service, His Majesty’s Revenue and Customs from the U.K. and IRS-CI from the U.S. Special thanks to the Department of Justice’s Office of International Affairs and Italy’s Ministero della Giustizia, Arma dei Carabinieri, Guardia di Finanza, and Interpol-Rome for their assistance.

IRS Criminal Investigation (IRS-CI) is the law enforcement arm of the IRS, responsible for conducting financial crime investigations, including tax fraud, narcotics trafficking, money laundering, public corruption, healthcare fraud, identity theft and more. IRS-CI special agents are the only federal law enforcement agents with investigative jurisdiction over violations of the Internal Revenue Code, obtaining a 90% federal conviction rate. The agency has 19 field offices located across the U.S. and 14 attaché posts abroad.