The jury reached a partial verdict in USA v. Manafort today. Paul J. Manafort Jr., President Donald Trump’s former campaign chairman, was found guilty of five counts of tax fraud, two counts of bank fraud and one count of failing to file foreign bank account reports (FBAR).

Initially, Manafort and his co-defendant, Rick Gates, had faced 12 counts, including conspiracy to launder money. However, in February, Mueller filed a superseding indictment for the pair which added 20 counts (you can read the superseding indictment here).

During the 16-day trial, prosecutors called 27 witnesses, including Manafort’s former business partner Rick Gates. Gates pleaded guilty by agreement in February to one count of conspiracy and one count of making false statements (you can read the plea agreement here).

Jurors were eventually presented with 18 charges to consider against Manafort. The charges focused on three areas: tax evasion, financial reporting, and bank fraud.

(You can read more about the specific charges here, or click below.)

After four days of deliberation, a jury found Manafort guilty of five counts of tax fraud, two counts of bank fraud and one count of failing to file foreign bank account reports (FBAR). All of those charges are, according to court documents, offense level 4. Typically, the more serious the crime, the higher base offense levels. Federal sentencing guidelines provide 43 levels of offense seriousness, but additional factors, such as the amount of a financial loss, can increase or decrease the base offense level and the sentence an offender receives.

The feds had alleged that Manafort and Gates performed work for the Ukrainian government that generated tens of millions of dollars in income. Manafort did not declare that income on his income tax returns, the feds claimed, and instead attempted to hide the money by disguising the income as “loans” from nominee offshore corporate entities.

It’s against the law to lie on your tax return. The feds needed to prove that Manafort earned and had access to the income, and signed a tax return under penalty of perjury that omitted that income. In other words, prosecutors had to follow the money back to Manafort.

Similarly, allegations of failure to file foreign bank account reports (FBAR) rest on proving a money trail. If a United States citizen has a financial interest in or signatory authority over any bank account or other financial account held in foreign countries, if the balance exceeds $10,000 at any time during the year, it must be reported. The government had to prove that Manafort had authority over foreign accounts for a jury to find him guilty of failing to report those accounts. That’s likely where some of the multiple entities Manafort and Gates allegedly set up helped Manafort’s defense: If the jury found that Gates had been responsible for some of the accounts, or if it was not clear whether Manafort had authority over those accounts, then he could not be found guilty of failing to report. In the end, the jury found Manafort guilty of one count of failure to report.

The government also claimed that Manafort, with Gates’ assistance, falsely inflated his company’s income by using fabricated profit and loss statements, and failed to disclose existing debt. A jury found the evidence credible enough to prove two of those counts.

The jurors failed to reach a consensus on ten additional charges. Earlier today, the jury sent a note to Judge T.S. Ellis III suggesting that they could not reach a verdict. The note read:

Your Honor, if we cannot come to a consensus on a single count, how should we fill in the jury verdict form for that count? And what will that mean for the final verdict? We will need another verdict form.

The judge returned a set of instructions and urged the jury to continue to work toward a verdict. Eventually, the judge declared a mistrial on the remaining ten counts.

If he had been found guilty of all of the charges, Manafort, who is 69, could have been sentenced to more than 100 years in prison. Now he awaits sentencing for less than half of those charges. A sentencing date has not been set as the prosecutors consider whether they will retry Manafort on the ten charges for which the jury did not reach a verdict.

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Kelly Erb is a tax attorney, tax writer and podcaster.

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