U.S. Justice Department indicts Texas promoter over alleged abusive tax shelter scheme

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Justice Dept indicts Texas promoter

Highlights

Roger Napoleon Grant indicted in the Eastern District of Texas for allegedly promoting and selling abusive trust tax shelters described as tax-free schemes.
Prosecutors allege Grant reported $80,521 in income for 2017-2022 while millions of dollars flowed to trust bank accounts he controlled and used for personal expenses.
Grant faces charges including tax evasion, aiding false returns, and filing false liens, with maximum penalties up to 10 years per false lien count following expanded DOJ anti-fraud measures.

Charges outline alleged trust shelter scheme

As reported by U.S. Department of Justice, Roger Napoleon Grant is charged in the Eastern District of Texas with tax crimes tied to the use, promotion and sale of what prosecutors describe as an abusive trust tax shelter.

The indictment alleges Grant used a multi-tiered structure involving at least two sham trusts and a purported charitable foundation, telling clients that income assigned to the trusts would be tax free. Prosecutors say he typically charged clients between $12,500 and $50,000 for the arrangement and provided the trust and foundation instruments, along with continuing guidance on how to use them.

For the years 2017 through 2022, the indictment alleges Grant assigned income from promoting the shelter to a purported business trust. Although he reported about $80,521 in total income during that period, prosecutors say millions of dollars were deposited into a bank account held in the trust's name, over which he had exclusive authority and which he routinely used for personal expenses.

Grant is charged with five counts of tax evasion, 10 counts of aiding and assisting the filing of false income tax returns, and 10 counts of filing false retaliatory liens. If convicted, he faces maximum penalties of five years in prison for each tax evasion count, three years for each false return count, and 10 years for each false lien count.

Investigation adds retaliation and enforcement focus

The indictment says Grant learned of the criminal investigation in April 2025 and then filed false liens against government officials. Those officials include the Attorney General of the United States, the Acting IRS Commissioner, the Acting U.S. Attorney for the District of Colorado, the Clerk of Court for the District of Colorado, and an attorney in the Justice Department's Civil Division.

IRS Criminal Investigation is investigating the case, while Acting Assistant Deputy Chief Boris Bourget and Trial Attorney Lauren K. Pope of the Criminal Division's Tax Section are prosecuting it. Assistant Attorney General Colin McDonald of the Justice Department's National Fraud Enforcement Division and U.S. Attorney Jay R. Combs of the Eastern District of Texas announced the case.

The department says the matter comes as it expands anti-fraud enforcement through the National Fraud Enforcement Division, announced on April 7. An indictment is an allegation, and Grant is presumed innocent unless proven guilty beyond a reasonable doubt in court.

Our earlier coverage of U.S. Treasury sanctions detailed OFAC’s designation of seven individuals and entities accused of supporting the IRGC’s overseas weapons procurement network. We outlined how the measures block U.S.-jurisdiction property, restrict dealings by U.S. persons, and raise secondary-sanctions and compliance risks for foreign financial institutions and global trade intermediaries.

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