Practitioners and students of tax crimes know that most of the commonly charged tax crimes have an element of willfulness which the Supreme Court interpreted in Cheek to mean a voluntary [...]
So once upon a time, many of us were comfortable thinking that it was possible to have Private equity fund managers take a share of the profits of the partnership as the equity portion of their [...]
FBI Charge 6 With Running $500 Million Offshore Laundering Scheme…..Rule of Thumb – If it Seems To Good to be True? Don’t walk away….RUN!!!!
Federal prosecutors charged six men Tuesday with running a complicated offshore scheme that allegedly enabled clients to manipulate stocks, avoid U.S. taxes and launder hundreds of millions of [...]
FATCA is a term that must be familiar to anyone who deals with US institutions or US persons. Few of us in the International Business Structuring space however, truly grasp the implications. It [...]
I don’t think I can count the number of times an American expat has explained their situation and then asked the question – “what’s the chance of the IRS finding [...]
FBAR stands for Foreign Bank Account Report. It must be filed by “U.S. persons” if the person has an interest in, or signatory authority over a foreign financial account, and the [...]