Archive | September, 2016

Expatriation and Taxation

September 30, 2016  |   Posted by :   |   Expatriation   |   0 Comments

Taxation of US Citizens has varied over the years, with terms shifting periodically from one methodology to another, but it remains today that expatriates face substantial taxation on assets at point of departure and upon renouncing citizenship. For US citizens considering such a move, they need to be mindful of not only the tax but […]

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IRS Tax Audits: Special Tax Compliance Rules – Foreign Activities

September 29, 2016  |   Posted by :   |   International Tax Planning   |   0 Comments

Ownership (legitimate) of foreign entities by US taxable residents and the inherent US reporting for these trusts, companies, partnerships, foundations, hybrid companies etc. is a virtual minefield in terms of compliance. The forms required are many and failure to report- or report correctly- can result is substantially punitive consequences. Clients and their advisors are well […]

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Tax Planning for Sexual Harassment Claims: US Taxpayer Foreign Gifts

September 28, 2016  |   Posted by :   |   Sexual Harassment   |   0 Comments

Recently, I published an article in CA CEO and Lorman Education Services on the topic, “Tax Planning for Sexual Harassment Claims.” When the parties involve a payor who is an international (i.e. non-US person) intricate tax reporting rules may arise under IRS Form 3520 which requires an annual report be filed for US taxpayers who […]

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Update: Panama Papers September 2016

September 27, 2016  |   Posted by :   |   Panama Papers   |   0 Comments

The Panama Papers were released in April 2016, outing the world’s wealthiest people, including celebrities, politicians and business leaders for hiding their wealth through Panama Law Firm, Mossack Fonseca, setups in world tax havens (currently 90 known world tax havens). The explosive revelations subsequently have included: 1) Up to $34 Trillion in Wealth, owned by […]

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IRS Criminal Tax Crimes 2016 – Nowak

September 26, 2016  |   Posted by :   |   Tax Evasion   |   0 Comments

A federal jury convicted Jeffrey Nowak (former owner of Las Vegas liquor store, Super Liquors on the strip) for nearly $4m in unreported income that he failed to report. Between 2006-2009, Nowak skimmed cash receipts from his liquor store, which he did not report on his tax returns. The jury found him guilty of three […]

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IRS Criminal Tax Case 2016: Father Hien Minh Ngun

September 25, 2016  |   Posted by :   |   Tax Evasion   |   0 Comments

A Catholic Priest, Father Hien Minh Ngun (San Jose, CA) plead guilty to tax evasion. Over 4 years (2008-2011) he stole funds from parishioners. He took funds donated to his church and deposited them into his personal bank account. He did not tell his tax preparer, did not keep records, filed false income tax returns […]

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IRS Off-shore Tax Evasion: 5th Amendment (Greenfield)

September 24, 2016  |   Posted by :   |   Tax Evasion   |   0 Comments

Forbes (8/3/16) reported that the 2d Circuit Court of Appeals ruled that the 5th amendment protects taxpayer Steven Greenfield from turning over documents (from 2001) related to offshore tax evasion in Liechtenstein (a tiny European Alpine country once fabled for its bank secrecy laws, but still remains a favored place by billionaires to stash their holding […]

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IRS Offshore Tax Evasion and the 5th Amendment

September 23, 2016  |   Posted by :   |   Tax Evasion   |   0 Comments

Under the 5th Amendment, a party does not have to provide evidence that incriminates them. However, there are exceptions including the “Required Records Doctrine” which states that when certain conditions are met, records required to be maintained fall outside the scope of the privilege. The US Court of Appeals (9th Cir.) in the case In […]

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Wolfe Law Group Releases Two Books on the Panama Papers

September 22, 2016  |   Posted by :   |   Panama Papers   |   0 Comments

Gary S. Wolfe of The Wolfe Law Group is proud to announce the release of two eBooks on the Panama Papers: 1. The IRS/Panama Papers: Money Laundering and Tax Evasion 2. The IRS/Panama Papers: US Taxpayers with Offshore Entities On 9/27/16 the European Union Parliament Committee of Inquiry on Money Laundering and Tax Evasion will […]

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Tax Evasion & Money Laundering: Foreign Persons

September 21, 2016  |   Posted by :   |   Tax Evasion   |   0 Comments

Under 18 USC 1956 (f), there is extraterritorial jurisdiction over the conduct prohibited if: 1) The conduct is by a US citizen, or, in the case of a non-US citizen, the conduct occurs in part in the US; and 2) The transactions or series of related transactions involves funds or monetary instruments of a monetary […]

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