Archive | International Tax Planning

The IRS and Married Couples: Real Estate

June 15, 2017  |   Posted by :   |   International Tax Planning,IRS Tax Audits   |   0 Comments

Two new cases in 2017 have been recently decided by the US Tax Court, which involves married couples with Real Estate: 1. Asad, TC Memo. 2017-8: Husband & Wife who each owned rental property deducted large losses on their joint tax returns. They later divorced. As per the divorce agreement, the divorced couple wanted to […]

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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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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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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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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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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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International Tax Awards 2017

January 09, 2017  |   Posted by :   |   International Tax Planning   |   0 Comments

I am pleased to announce that I have just received my 18th & 19th international tax award. The 19 awards are from 8 different global expert societies. #18) International Tax Lawyer of the Year (2017) from Global Business Magazine/Prof. Sector Network (over 200,000 advisors worldwide). #19) On 1/9/17 I received notice that my firm was […]

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Tax Planning Beyond the Grave

January 03, 2017  |   Posted by :   |   International Tax Planning   |   0 Comments

Offshore Investment Magazine is widely regarded within the international financial marketplace as the leading journal for wealth management professionals. I am pleased to announce that they have recently published my article, Tax Planning Beyond the Grave – The Michael Jackson Case, as their lead cover story in the Nov/Dec 2016 issue.

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The IRS & Celebrity Tax Issues: Michael Jackson & Ronald Isley

December 22, 2016  |   Posted by :   |   International Tax Planning   |   0 Comments

The IRS is currently litigating with the Estate of Michael Jackson which they assert owes over $700m in tax, penalty and interest (which if upheld could potentially wipe out his estate and leave his heirs with no inheritance). At the heart of the case is the value of Jackson’s celebrity image, name and likeness (I […]

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Investment Tax Planning for US and International Investors

December 21, 2016  |   Posted by :   |   International Investors,International Tax Planning   |   0 Comments

US and International Investors who invest in the US or immigrate to the US face the same issues: 1. Worldwide US income, estate and gift tax reporting and taxes due. 2. Disclosure of foreign bank accounts (over $10k by annual FBAR filings) and disclosure of foreign financial assets over $50k (FATCA Form 8938, attached Form […]

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