Oleg Tinkov became a U.S. citizen on September 10, 1996. By the time TCS Group Holding entered the IPO in October 2013, Tinkov was the majority shareholder of the company. On April 5, 2013, he became the owner of the Beckett Group Ltd., registered in the British Virgin Islands (BVI). And at the end of May of that year, the Beckett Group became the owner of two more companies registered at the BVI - Tadek Holding & Finance S.A. and Tacos Invest & Finance Inc. According to the indictment, by the time of the IPO of TCS Group Holding on October 25 (the first day of trading in TCS Group Holding shares on the London Stock Exchange - October 22, 2013 - approx. Forbes), Tadek and Tacos owned 93 million and 10 million shares of TCS Group Holding, respectively. This accounted for more than 60% of all TCS shares. During the IPO, Tinkov and his structures sold shares for $ 199 million. Thus, after the IPO, Tinkov owned offshore companies 92 million shares of TCS Group, whose market value exceeded 1 billion on October 27, 2013. On October 28, Tinkov withdrew from US citizenship.
According to U.S. law, for individuals whose fortune exceeds $ 2 million and who decide to withdraw from US citizenship, all property is considered to be sold at a market price the day before they withdraw from citizenship (in the case of Tinkoff, this is October 27, 2013). In US law, this is called "constructive selling." All profits from this “constructive sale” must be taxed in the year you leave the country. Tinkov, as stated in the indictment, not only did not provide the correct information about his assets, but also did not reflect the profit from the “constructive sale” in the tax return.
What TCS Group Holding Says
For the first time, TCS Group Holding announced a lawsuit initiated by the US tax authorities with the participation of Oleg Tinkov in London on February 28. In its disclosure on the London Stock Exchange, the company indicated that Oleg Tinkov took part in the hearings in February-April 2020. At the same time, TCS emphasized that Tinkov participated in the hearings as a private individual, and this does not affect the activities of the group company (Tinkoff Bank, Tinkoff Insurance and Tinkoff Mobile). A few days later, on March 2, the company confirmed the information appeared in the Daily Express tabloid that Tinkov had paid a deposit and would remain in London for the duration of the hearings. "Mr. Tinkov informed us that his team of lawyers is working to resolve this issue as quickly as possible," the report said.
Since the close of trading on the London Stock Exchange on February 27, TCS Group Holding shares have fallen in price by almost 7%.