Archive by Author

The Wolfe Law Group Press Kit

April 13, 2017  |   Posted by :   |   International Tax Planning   |   0 Comments

The Wolfe Law Group is an international array of legal and tax experts providing collaborative services for Global High Net Worth Investors on a per client basis. Gary S. Wolfe, A Professional Law Corporation has over 35 years of experience providing clients with expertise for IRS Civil and Criminal Tax Audits, International Tax Planning, and […]

Read More »

Tax Planning and Legal Authority

April 10, 2017  |   Posted by :   |   IRS Tax Audits,Tax Evasion   |   0 Comments

The US Supreme Court has a long history of supporting legal tax planning while disavowing illegal tax evasion (which has both civil and criminal consequences). Please see the authorities cited below. In 1864, in the case of US v. Isham 84 US 496 (1864) the US Supreme Court considered the Stamp Duty (Tax) and stated […]

Read More »

US Tax Planning for High Net Worth Investors​

March 28, 2017  |   Posted by :   |   Asset Protection,High Net Worth Investor,International Tax Planning   |   0 Comments

Helvering v. Gregory In the landmark case, Helvering v. Gregory 69 F.2d 809, 810 (2d. Circuit Court of Appeals, 1934), reversed a decision of The Board Of Tax Appeals (precursor to US Tax Court) see: Gregory v. Commr. 27 B.T.A. 223 (1932), and found against the taxpayer (Mrs. Gregory); Hand’s decision was affirmed by the […]

Read More »

Investment Tax Planning: Private Annuity – Life Insurance

March 20, 2017  |   Posted by :   |   International Tax Planning   |   0 Comments

The “mechanics” are as follows: 1) For clients with over $3m (investable) have them consider funding a Private Annuity (“PA”) (Nassau, governed under Puerto Rico law) for asset protection, investment diversity (including closely held companies) and confidentiality. The PA funds a non-modifed endowment contract (“non-mec”) Private Placement Life Insurance (“PPLI”) over 5 separate years so […]

Read More »

IRS Tax Audits – Criminal Tax (2017)

March 16, 2017  |   Posted by :   |   IRS Tax Audits   |   0 Comments

The IRS reported that in fiscal year 2016 they initiated 3,395 federal criminal tax cases thru the IRS/Criminal Investigation Division (which is the only federal law enforcement agency with jurisdiction over federal tax crimes). The focus of these cases included: money laundering, public corruption, cyber-crimes. For FY 2016, the IRS/CI conviction rate was 92%. The […]

Read More »

New IRS Tax Rules (2017)

March 15, 2017  |   Posted by :   |   IRS Tax Audits   |   0 Comments

In IR-2016-139 (10/25/16) for tax year 2017 the following new IRS tax rules apply: 1) Standard Deduction: Singles: $6,350 (2016: $6,300) Married: $12,700 (2016: $12,600) 2) Personal Exemption Singles: $4050 (2016: same) This exemption is subject to a phase out and is reduced by 2% for each $2500 of Adjusted Gross Income over threshold AGI […]

Read More »

The Panama Papers: Street Protests in Panama

February 22, 2017  |   Posted by :   |   Panama Papers   |   0 Comments

On 2/19/17 thousands of Panamians protested in the streets carrying signs “No More Governments of Thieves and the Corrupt”. They were demonstrating over the most recent scandal emerging from the Panama Papers the Brazilian firm, Odebrecht who paid $788m in bribes to win construction contracts in 12 countries (including $59m in bribes in Panama). Odebrecht […]

Read More »

IRS Offshore Voluntary Disclosure Program: Declines and Withdrawals

February 21, 2017  |   Posted by :   |   OVDP   |   0 Comments

Taxpayers with undisclosed offshore holdings who applied for the IRS Offshore Voluntary Disclosure Program (OVDP) through the pre-clearance process but were either denied access to the OVDP, or later withdrew from the program face increased risks. On February 1, 2017 the IRS Large Business and International Division of the IRS released a 13-item list for […]

Read More »

Panama Papers Update: Mossack & Fonseca Law Firm Founders Arrested

February 16, 2017  |   Posted by :   |   Panama Papers   |   0 Comments

On 2/10/17 The Guardian reported that Juergen Mossack & Ramon Fonseca, founders of Panamanian law firm Mossack Fonseca were arrested and jailed following Panama probe into creating companies linked to Brazil corruption in the bribery case of Brazilian Company Odebrecht. The case is part of the sprawling Brazilian Lava Jato corruption scandal. The Panama Papers […]

Read More »

IRS Tax Audit Rates (2017)

February 08, 2017  |   Posted by :   |   IRS Tax Audits   |   0 Comments

In a groundbreaking study the TaxFoundation.org released a study of IRS tax audits for the 2015 Fiscal Year (thru 9/30/15, the most recent tax year for which IRS tax audit statistics have been released), which revealed the following: 1. The overall IRS audit rate has dropped from 1.1% (2010), 1 in 90 taxpayers to .8% […]

Read More »