Entries by Manager

IRS Wins Against Wells Fargo’s Tax Shelter Scheme | Int’l Tax Lawyers MN

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 […]

IRS International Tax Campaigns | International Tax Attorney Houston

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 […]

IRS Compliance Campaigns | US International Tax Attorney and Lawyer

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. […]