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On May 25, 2017, the IRS sealed another victory against the infamous abusive tax shelter known as STARS (Structured Trust Advantaged Repackaged Securities). The actual victory occurred on November 17, 2016, when a jury in Minnesota found Wells Fargo guilty of engaging in abusive tax shelter and determined that Wells Fargo was not entitled to […]
On May 3, 2017, the IRS scored an important victory in United States v. Little, 2017 U.S. Dist. LEXIS 67580 (SD NY 2017) by defeating a Motion to Dismiss FBAR charges made by the defendant, Mr. Michael Little. The motion was based on an argument that is often used by opponents of FBAR penalties – […]
On March 23, 2017, the IRS scored another major victory against using Belize bank accounts to hide income. On that day, Mr. Casey Padula pleaded guilty to conspiracy to commit tax and bank fraud, including using Belize bank accounts to conceal almost $2.5 million. Facts Concerning Using Belize Bank Accounts to Commit Tax Fraud According […]
Five of the thirteen new IRS Campaigns directly target US international tax noncompliance. In this essay, I would like to provide a brief overview of these five IRS International Tax Campaigns. In the future articles, I will explain each of these campaigns in more detail. IRS International Tax Campaigns: Background Information After multiple years of […]
On January 31, 2017, the IRS announced a complete new approach to tax enforcement – Issue-Focused IRS Compliance Campaigns. A total of thirteen IRS compliance campaigns were announced; all of them will be administered by the LB&I (Large Business and International) division of the IRS. Let’s explore in more detail this highly important IRS announcement. […]