What Happens in Vegas Stays in Vegas
The catch phrase in the movie Jerry McGuire was “Show Me the Money!” It now looks like prosecutors are adopting the same mantra and are enjoying success in courts indicting those that attempt to hide money and avoid paying taxes either in the U.S. or abroad. In the past, it was a given that an […]
What If …
What if Adam and Eve had admitted that they ate from the Tree of Knowledge of Good and Evil, instead of pointing the finger at anyone else, and anything else, that happened to be there at the time? Would they still be lounging in the Garden of Eden today, munching on pomegranates and perusing through […]
IRS Updates Rules For Foreign LLC’s
The IRS recently updated its rules for foreign LLC’s. The updates can be found here. The relevant portions are contained below: A Limited Liability Company (LLC) is a business structure allowed by state statute. Each state may use different regulations, and you should check with your state if you are interested in starting a Limited Liability […]
From Convicted Felon to Government-Made Millionaire: The Man Who Ended the Tradition of Bank Secrecy and Got Rich in the Process
Meet Bradley Birkenfield. Mr. Birkenfield, a former Swiss banker, was released from federal prison three years ago after serving 2½ years for helping wealthy American clients hide millions of dollars from the U.S. government. Five weeks after his release from prison, Birkenfield was sitting on his couch wallowing in his misery, recognizing that he was unemployable as a private banker anywhere. But little did […]
Streamlined Testimonial
Dear Michael, Your excellent work on the streamlined procedure and related certification , and your explanations and discussions with me, were very much appreciated. I am glad to have had the benefit of your experience and competence in completing the process. With every good wish, R.C.
OVDP & Double Counting: Traps for the Unwary
Accounting for “double counting” is not child’s play. Your tax attorney will need the following information in order to complete his or her review of your double counting issue. These steps must be repeated for every year in which you believe that there is a double counting issue. For each transfer, you should provide the following: […]
Tax Planning on the Edge – Ride or Die in the International Tax Arena
The U.S. economy has become more global, lining up in the race to the top. However, with multinational economic activities revving their gears, some tax practitioners are growing fast and furious. To them, it doesn’t matter if you win by an inch or a mile; winning is winning. As a result, some choose to violate […]
Ms. Fournie Shows Fortitude In Fight Against IRS
A Message From Uncle Same To U.S. Taxpayers: No One Is Above the Law When It Comes to Filing Timely And Accurate Income Tax Returns
Just in time for the April 15, 2015 tax filing deadline, the IRS issued a press release entitled, “Justice Department Reminds Taxpayers that No One Is Above the Law or Below the Radar.” No further commentary is necessary. The title says it all. Click here to read the article.
IRS-CI Publishes 2014 Annual Business Report
IRS-CI recently published its 2014 Annual Business Report. It contains statistics regarding the conviction-rate for 2014 and is very insightful. Click here to view it.