Archive by Author

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 […]

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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 […]

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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 […]

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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 […]

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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 […]

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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 […]

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IRS Tax Audit Rates (2017)

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

In a groundbreaking study the 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% […]

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Tax Planning for US Investors – Doubling Net Return on Investment

February 02, 2017  |   Posted by :   |   Asset Protection,International Tax Planning   |   0 Comments

By David E. Richardson and Gary S. Wolfe US investors (incl. US resident citizens, Green Card holders or income tax residents under the substantial presence test and any US citizen located abroad) face significant US Income, Estate and Gift tax issues on their investment portfolios namely: 1) Imposition of Federal and State (e.g. CA) “blended […]

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IRS Offshore Voluntary Disclosure Program – as amended 7/1/14

January 25, 2017  |   Posted by :   |   OVDP   |   0 Comments

Under the IRS Offshore Voluntary Disclosure Program (“OVDP”) 7/1/14 amendment the taxpayer who enters the program increases their cost since the payment is now due up front for all taxes, penalty and interest. The OVDP is now quite expensive and may wipe out the entire taxpayer offshore account. The IRS Offshore Voluntary Disclosure Program Frequently […]

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IRS Tax Audit Risks – 2016

January 19, 2017  |   Posted by :   |   IRS Tax Audits   |   0 Comments

On 12/19/16 Fox Business News published “9 Tax Audit Red Flags for the IRS” by Sean Williams. As a background, the Tax Foundation found that the US Tax Code is now 10.1m words. The instructions to complete a basic Form 1040 are more than 100 pages long. Although historically the IRS only audits about 1% […]

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