The Foster Dunhill program, as it was known (it actually involved quite a few companies but Foster Dunhill was the most prominent), was a widespread program of blatant tax fraud perpetrated by a number of individuals, including Stephen Donaldson, Sr., and Duane Crithfield. In essence, privately-owned American businesses paid exorbitant premiums for various insurance coverages to an offshore insurance company controlled, taking a deduction against income for the policies, and then the offshore insurance company purchased an offshore annuity or cash-value policy for the business owner to give them access to their moneys.
Donaldson and Crithfield were indicted for tax fraud, and, as my second article discussed, eventually entered guilty pleas. After that article was written, however, a strange twist of fate occurred as the U.S. District Judge rejected their guilty pleas, and not too long after that the pair went to trial. At a bench trial wherein the judge made the findings of fact (as opposed to a jury trial where laypersons do that), the court on July 12, 2017, entered an Order which found Donaldson and Crithfield guilty of all counts of the crimes charged.
You can, and should, read the Order here.