Offshore Tax Evasion: U.S. Clients Of Trident Trust Target Of IRS John Doe Summons

The Department of Justice and the Internal Revenue Service have recently reaffirmed their strong commitment to pursuing offshore tax evasion through the use of powerful investigative tools. One such tool is the IRS John Doe Summons. On Dec. 23, 2024, the United States District Court for the Southern District of New York granted the IRS authority … Continue reading Offshore Tax Evasion: U.S. Clients Of Trident Trust Target Of IRS John Doe Summons →

American Taxpayer Abroad: U.S. Social Security, What You Need To Know

The world of work has changed dramatically. No longer confined to an office in a fixed location, people are working from many different locales and exploring varied work lifestyles. The possibilities are vast - working in foreign countries, living as a digital nomad, owning one’s own company abroad, are but a few. If you are an … Continue reading American Taxpayer Abroad: U.S. Social Security, What You Need To Know →

Mr. Taxman @IRS: Looks Like My Money, But It Really Isn’t…

The Department of Justice and the IRS are champing at the bit to nail former defense contractor, Douglas Edelman, and his French wife Delphine Le Dain. They were charged with schemes to defraud the United States and evade taxes on more than $350 million using a complicated nominee arrangement. "Oh Mr. Taxman, I know it looks like my … Continue reading Mr. Taxman @IRS: Looks Like My Money, But It Really Isn’t… →

The New York Times, USSCt Justice Clarence Thomas, Juicy Gifts & the Tax Lessons!

Sometimes I like to bring up issues occurring strictly in the USA and take a peek at how the US tax rules would shake out if foreigners were involved in the transactions. It always makes for a much more complicated analysis. Here is one for today! Let’s look at the juicy story of Justice Clarence … Continue reading The New York Times, USSCt Justice Clarence Thomas, Juicy Gifts & the Tax Lessons! →

Malta Pension Plan – IRS Knocks It Out.. and Yes, “I Told You So…..”

Just in time for Christmas, we have two big gifts. Both relate to Malta Pension Plan schemes. If you are too busy to read the post because of the Christmas rush, in a nutshell, they've just been knocked out and the Internal Revenue Service (IRS) is hot on the trail for taxpayers who used them! … Continue reading Malta Pension Plan – IRS Knocks It Out.. and Yes, “I Told You So…..” →

Foreign Foundations — What are they for US Tax Purposes? Should I Care? Recent Court Case Lays it Out

Today’s post looks at the case of Rost v United States, No 119-CV-0607-RP 2021 BL 435976 (WD Tex., Austin Div., September 22, 2021). In the Rost case, the Internal Revenue Service ("IRS") assessed close to USD597,000 in civil penalties for a US taxpayer’s failure to file IRS Forms 3520 and 3520-A, information reporting with regard … Continue reading Foreign Foundations — What are they for US Tax Purposes? Should I Care? Recent Court Case Lays it Out →