Tax shelter promoters plead guilty to conspiracy to defraud the United States

Date: March 13, 2026

Contact: [email protected]

Washington - Two men, one from Texas and one from Nevada, pleaded guilty this week in separate cases to conspiring to defraud the United States by promoting abusive tax shelters.

United States v. Aanand Shukla (Western District of Texas)

On March 11, 2026, Aanand Shukla, of Jonestown, Texas, pleaded guilty to conspiracy to defraud the United States related to his efforts to promote a fraudulent tax shelter to business owners across the country. According to court documents and statements made in court, from 2017 to 2025, Shukla and his co-conspirators promoted, sold and personally used an abusive trust tax shelter that promised clients - for fees as high as $225,000 - they could "own nothing, control everything" and eliminate taxes on nearly all of their business income while maintaining full control over their money. Shukla marketed the scheme nationwide through seminars, webinars, podcasts and direct sales pitches. He instructed clients to restructure their companies so approximately 98% of their business income flowed through layered trusts and a private family foundation. He told clients to run personal expenses - such as vehicles, entertainment and mortgage payments - through trust accounts and claim those expenses as deductions. Shukla typically sold these trust packages to clients for $25,000 to $55,000, created trust documents, trained other promoters and referred clients to tax preparers he had personally selected and knew would participate in the scheme.

Shukla contributed to the filing of at least 321 false tax returns, which concealed more than $27 million in client income and $3.7 million of his own income. His crimes caused more than $8.7 million in losses to the United States.

United States v. Carl Dimailig (District of Nevada)

In a separate case, on March 10, 2026, Carl Dimailig, of Henderson, Nevada, also pleaded guilty to conspiring to defraud the United States. According to court documents and statements made in court, from 2018 to 2025, Dimailig conspired with two other promoters to market and implement an abusive trust tax shelter designed to conceal from the IRS nearly all of their clients' taxable income. Dimailig and his co-conspirators helped more than 35 clients restructure their businesses so that 98% of business income flowed through layered sham trusts and a fake "private family foundation." The clients, however, continued to completely control and spend the money at their discretion. Dimailig prepared false income tax returns that disguised personal expenses as trust expense deductions and claimed false charitable contributions. He also used the same scheme for himself from 2019 through 2023, evading $127,646 in personal income taxes.

In total, Dimailig prepared and filed approximately 120 false tax returns with the IRS, which concealed more than $34 million in client income and $400,000 of his own income, causing more than $9.6 million in losses to the United States.

Shukla's plea was taken by U.S. Magistrate Judge Dustin M. Howell for the Western District of Texas and must be accepted by a U.S. district court judge. Dimailig will be sentenced separately on Sept. 10, 2026. Each defendant faces a maximum penalty of five years in prison for conspiring to defraud the United States. A federal district court judge will determine any sentence after considering the U.S. Sentencing Guidelines and other statutory factors.

IRS Criminal Investigation is investigating both cases.

Trial Attorneys Lauren K. Pope and Boris Bourget of the Criminal Division's Tax Section are prosecuting both cases.

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. It is the only federal law enforcement agency with investigative jurisdiction over violations of the Internal Revenue Code. IRS-CI has 18 field offices located across the U.S. and maintains an international presence through attaché posts abroad.