Houston billionaire Robert Brockman, who made his fortune selling software, has been charged with hiding $2 billion in income from the IRS over two decades as part of the biggest ever tax fraud case against an American, federal prosecutors announced Thursday. “Complexity will not hide crime from law enforcement,” U.S. Attorney Dave Anderson said at a Thursday press conference, adding, “We will not hesitate to prosecute the smartest guys in the room.” Prosecutors also announced that billionaire Robert E. Smith, the founder of Austin-based Vista Equity Partners who was under investigation for potential tax crimes, had helped them with their case against Brockman in exchange for a non-prosecution agreement. Anderson said Brockman, 79, hid his money through offshore entities in the Caribbean and broke “a promise to investors that he would not buy or sell his own company’s debt.” He’s been charged with money laundering, conspiracy, wire fraud, and tax evasion.