Well. God help Manafort, even though he has been a rich worldly man. That sounds like one of the nastier lurking bombs in the tax code, though any accountant worth the name will know about the need. I guess the bomb could trigger on a rich man who insists on doing it all himself. Frankly I would ask about due process if challenging the criminal aspect in the USSC. “Having a lot of money and not knowing quite what to do with it” oughtn’t to be a crime.