{"id":15177,"date":"2026-06-12T13:09:43","date_gmt":"2026-06-12T16:09:43","guid":{"rendered":"https:\/\/ar.andersen.com\/the-loopholes-in-adornis-tax-strategy-to-avoid-prison-for-tax-evasion-iprofesional-press\/"},"modified":"2026-06-12T15:12:55","modified_gmt":"2026-06-12T18:12:55","slug":"the-loopholes-in-adornis-tax-strategy-to-avoid-prison-for-tax-evasion-iprofesional-press","status":"publish","type":"post","link":"https:\/\/ar.andersen.com\/en\/the-loopholes-in-adornis-tax-strategy-to-avoid-prison-for-tax-evasion-iprofesional-press\/","title":{"rendered":"The Loopholes in Adorni’s Tax Strategy to Avoid Prison for Tax Evasion | IProfesional Press"},"content":{"rendered":"\n

F\u00e9lix Rolando<\/strong> discusses in iProfesional<\/em> <\/strong>the tax situation reported by Manuel Adorni and the potential implications of voluntarily filing amended tax returns in the face of a possible criminal tax complaint.<\/p>\n\n

This analysis makes it possible to examine how the taxpayer\u2019s conduct, the timing of the correction, and the supporting documentation factor into the assessment of a potential tax criminal liability.<\/p>\n\n

We reproduce below the complete article published by iProfesional<\/em>:<\/p>\n\n

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<\/p>\n\n

Chief of Staff Manuel Adorni has devised a strategy to avoid prison. On the one hand, he is pleading guilty to tax evasion rather than corruption, structuring a strategy that will prevent criminal charges from being filed<\/strong>. On the other hand, he justifies everything by citing his ownership of Bitcoin for up to one year, for which there is no penalty, according to experts\u2019 analysis. <\/p>\n\n

From a criminal tax law perspective, two key elements of Adorni\u2019s strategy to avoid prison are voluntary disclosure and enrollment in the Simplified<\/strong> Income Tax<\/strong> Regime<\/strong>.<\/p>\n\n

How does voluntary surrender interact with a criminal complaint?<\/h3>\n\n

“I submitted the sworn statements before taking office, as well as the amended statements for previous years, to the Anti-Corruption Office,” Adorni said in a television interview.<\/p>\n\n

The documentation includes assets that had not been included in previous disclosures, including approximately $513,000 derived from investments made with Bitcoin between 2013 and 2018, which now constitute the largest financial asset disclosed by the official.<\/p>\n\n

The process involved reviewing investments, inherited assets, real estate transactions, and changes in net worth<\/strong> over a period of several years.<\/p>\n\n

“With regard to the possibility of criminal charges, the analysis suggests that no criminal offense would have been committed if the taxpayer chooses to<\/strong> voluntarily rectify<\/strong> the situation,” says F\u00e9lix Rolando of Andersen Argentina.<\/p>\n\n

“Since there is no ongoing audit and no criminal proceedings have been initiated, the voluntary correction of the sworn statements eliminates the intent to deceive or defraud<\/strong> necessary to defraud the government or the public treasury,” he explains.<\/p>\n\n

What are the benefits of enrolling in the Simplified Income Tax Program?<\/h3>\n\n

In a misleading way, he stated that “I could have registered for tax exemption to avoid paying anything, but that\u2019s not going to happen<\/strong>. I\u2019m going to pay the taxes I owe.” <\/p>\n\n

“Under the Tax Amnesty Program, neither my wife nor I will launder a single dollar<\/strong>. I am filing all my amended tax returns under the general tax regime. I will pay all my taxes,” Adorni stated. <\/p>\n\n

From a technical standpoint and without analyzing the specific case, Alberto Mastandrea of BDO Argentina notes that the Tax Amnesty Law introduces a regularization mechanism that seeks to decriminalize<\/strong> tax evasion exclusively, using the Simplified Income Tax Regime as a legal shield against potential criminal charges for prior periods.<\/p>\n\n

“The key to this benefit is enrolling in the Simplified Tax System and filing the tax return for the so-called ‘base period,'” he argues, and Mastandrea adds:<\/p>\n\n