Archive by Author

Theft and Fraud is a Casualty Tax Loss

May 22, 2017  |   Posted by :   |   Theft Loss   |   0 Comments

In 2017, major news stories surfaced of celebrity theft/fraud & casualty losses: Actor Dustin Hoffman and son Jacob were apparently defrauded of millions of dollars in a real estate investment with Paul Manafort’s son-in-law. Alanis Morisette had millions of dollars embezzled by her business manager, and in a separate in incident, lost several millions dollars of […]

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IRS Wealth Tax Squad – Update

May 17, 2017  |   Posted by :   |   High Net Worth Investor,IRS Tax Audits   |   0 Comments

The IRS released audit stats on their audits of high-wealth taxpayers (over $10 income or assets) by their recently formed special IRS tax unit, The Wealth Squad. For Tax year 2015, 450 IRS Wealth Squad audits were initiated. These IRS audits are expensive, and time consuming starting with an expansive IRS document request, which will […]

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Global HNW Investors: Stock-Bond Investment Portfolios

May 15, 2017  |   Posted by :   |   High Net Worth Investor   |   0 Comments

In my recent article Global High Net Worth Investors: US Investments, Immigration & Tax Planning I cited the L-1 Visa US immigration strategy as explained by my colleague, and co-author Mark Ivener, Esq. (pre-eminent US immigration attorney) as a tax efficient immigration and investment strategy (I have redacted Mark’s immigration explanation of the L-1 Visa, […]

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Global High Net Worth Investors: Asset Protection Strategy

May 04, 2017  |   Posted by :   |   Asset Protection   |   0 Comments

In a 2006 Wall Street Journal article it was revealed that high net worth investors had an investment tax planning “secret strategy”: they used private placement life insurance as a “tax free wrapper” for their liquid investment portfolios (stocks and bonds). The strategy has been cited as follows in an October 18, 2006 Wall St. […]

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Global High Net Worth Investors: Tax Evasion & Money Laundering (US/UK)

May 03, 2017  |   Posted by :   |   International Investors,International Tax Planning,Tax Evasion   |   0 Comments

In an unprecedented event, the United Kingdom is passing laws to seize real estate in London and the entire United Kingdom (over 2000 properties may be affected). Currently, billions of dollars of real estate have been purchased through offshore companies with undisclosed beneficial owners hiding illegal funds including tax evasion, bribes and massive thefts by […]

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Global High Net Worth Investors: US Investments, Immigration & Tax Planning

May 01, 2017  |   Posted by :   |   International Investors   |   0 Comments

For Global High Net Worth Investors who elect to immigrate to the United States, the pre-immigration planning is essential to minimize their tax implications. Under the current alternatives, an investor may gain a green card by an investment ($500k-$1m) and application for an EB5 Visa (which if in a regional center is a $500k investment, […]

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Antioch Attorney Disbarred Following Tax Evasion Charges

April 19, 2017  |   Posted by :   |   Tax Evasion   |   0 Comments

By Olivia Olsen, Northern California Record Mary Alice Nolan, an attorney practicing in Antioch, has been disbarred from the practice of law by the State Bar Court of California. The recommendation for disbarment was made by the Office of the Chief Trial Counsel (OCTC) in lieu of Nolan’s felony conviction of intercepting communications and tax […]

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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 […]

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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 […]

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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 […]

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