Archive | October, 2014

Criminal Tax Evasion: Burden of Proof

October 30, 2014  |   Posted by :   |   Tax Evasion,Unreported Income   |   0 Comments

The U.S. taxpayer’s exposure to civil penalty/criminal prosecution for unreported income and undisclosed foreign financial accounts is a “double-edged” sword with dual civil/criminal: Evidentiary Standards of Proof, Statute of Limitations, and Collateral Estoppel Issues. If the IRS first institutes a civil tax audit, they may summons evidence, which may support both a civil penalty (e.g. […]

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EB-5 Investor Visas and California Wineries

October 28, 2014  |   Posted by :   |   EB-5 Visa   |   0 Comments

Dear California Winery, Could your winery/vineyard use a $1million investment? Read on… The Wolfe Law Group is pleased to announce our 11/6/14 event, International Investors & California Wineries, at the world renowned Peninsula Hotel in Beverly Hills has sold out. The event is geared to international investors who wish to invest in California wineries. We […]

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Foreign Official Gives up Malibu Home in Federal ‘Kleptocracy’ Probe

October 24, 2014  |   Posted by :   |   International Tax Planning   |   0 Comments

By Timothy M. Phelps, LATimes.com The west African nation of Equatorial Guinea ranks among the world’s most impoverished places, but oil and gas deposits over the last two decades have led to extensive wealth, corruption and, in at least one case that became public Friday, the high life in Malibu. In a settlement filed in […]

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IRS Civil Tax Audits – Statute of Limitations

October 22, 2014  |   Posted by :   |   IRS Tax Audits   |   0 Comments

IRS civil tax audits generally have a 3 year statute of limitations which commences the later of: 1. Tax Return due date or, 2. Date of Tax Return Filing (evidenced by either electronic filing acceptance, or certified mail return receipt). The 3 year statute of limitations is extended to 6 years if 25% or more […]

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Tax shelter shake-up hits home

October 22, 2014  |   Posted by :   |   Tax Evasion,Unreported Income   |   0 Comments

A federal crackdown and a new act make life tougher for lawyers and accountants. By David Koeppel, Crain’s New York Criminal tax attorney Robert Fink views the conviction and sentencing of his client Dr. Michael Canale – on tax fraud charges in New York state federal court in 2012 – as representative of everything that’s […]

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Wolfe Law Group 2014 Update – Alfred Sapse

October 14, 2014  |   Posted by :   |   Uncategorized   |   0 Comments

The Wolfe Law Group is pleased to announce our recent affiliation with entertainment lawyer/film producer, Alfred T. Sapse (see resume below) Alfred Theodore Sapse, Esq. 149 Bacon Road Roxbury, CT 06783 860-248-5594 Education: 1982-UCLA-Bachelor of Arts-History 1985- Southwestern University School of Law Los Angeles-JD Bar Memberships: California and Connecticut Professional Experience (Attorney): Civil litigation with […]

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IRS 2014 Update: Offshore Tax Evasion

October 10, 2014  |   Posted by :   |   Tax Evasion,Unreported Income   |   0 Comments

1. Are Virtual Currencies The Next Offshore Bank Account for Tax Evaders? Unfortunately for would-be tax cheats, IRS Criminal Investigation has committed a team of IRS Special Agents to master Bitcoin and other virtual currencies. The IRS knows that to use Bitcoins, one needs a virtual wallet along with private keys and public addresses. Unknown […]

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Switzerland and Offshore Tax Evasion

October 07, 2014  |   Posted by :   |   Tax Evasion   |   0 Comments

In a recent study, Gabriel Zucman, Asst. Prof., London School of Economics (and international author who works with Thomas Piketty and Emanuel Saez) estimated: 1) Switzerland has $2.4 Trillion in global offshore funds, 1/3 of projected $7.6 Trillion total (which is 8% of projected global financial assets). 2) 60% of foreign owned deposits in Switzerland […]

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