Criminal Tax Evasion: Part 2, Offshore Accounts & Willfulness

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Article By: Gary Wolfe, The Wolfe Law Group

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Tax Advisors (Attorneys/CPAs) who render tax advice to a taxpayer for offshore accounts (or other tax matters) may have no attorney-client privilege and may themselves be subject to criminal penalties.

US Taxpayers with undisclosed offshore accounts face a myriad of civil and criminal tax penalties. In addition, the Taxpayer may not have the attorney-client privilege for confidential communications if the professional services from legal counsel was for tax advice and the IRS investigates taxpayer for criminal tax evasion.

Under IRC Sec. 7525 (effective date 7/22/98), there is no attorney-client privilege for tax advice rendered if the IRS pursues a criminal tax investigation. The implications for the US Taxpayer and advisors include the following:

  1. US Taxpayers with undisclosed offshore accounts and/or unreported income (from offshore or domestic accounts) may not be able to assert an attorney-client privilege if questioned by the IRS;
  2. Their tax advisor (i.e. Attorney or CPA), who rendered tax advice to them, may be unable to refuse to answer IRS inquiries or produce Taxpayer records;
  3. Under 18 USC Sec. 371(conspiracy to commit tax evasion) when 2 or more parties collude to evade taxes due they may be held liable for a criminal tax conspiracy and face felony charges (5 years in jail), known as a “Klein conspiracy”;
  4. Under Treasury Dept. Circular #230 (the rules governing tax practice before the IRS), Sec 10.21 requires a tax practitioner, who is aware that a taxpayer is non-compliant with federal tax law to advise the taxpayer of both the taxpayer tax non-compliance and the penalties for continued tax non-compliance, or the tax practitioner faces suspension or disbarment for their tax practice before the IRS.
  5. Under 18 USC Sec. 4, Misprision of a Felony: “Whoever has knowledge of actual commission of a felony…. must refer the matter to a judge or other civil or military authority… or is subject to “be fined, or imprisoned not more than 3 years or both (effective 6/25/48).
    The term “tax advice” means advice given by an individual with respect to a matter that is within the scope of an individual’s authority to practice (IRC Sec. 7525 (a) (3) (B). Under IRC Sec. 7525 (a)(1): “with respect to tax advice, the same common law protections of confidentiality, which apply to a communication between a taxpayer and an attorney, shall also apply to a communication between a taxpayer and any federally authorized tax practitioner (“FAPT”), to the extent the communication would be considered a privileged communication if it were between a taxpayer and an attorney”.

A FAPT (federally authorized tax practitioner) means an individual authorized under federal tax law to practice before the IRS where the practice is subject to federal regulation under 31 USC Sec. 330 (IRC Sec. 7525 (a)(3)(A). The term FAPT includes an attorney, CPA, an enrolled agent, or an enrolled actuary. The FAPT does not apply to accountants who are not CPAs (unless the accountant qualifies as an enrolled agent). See Treasury Dept Circular 230, IRS Pub 947).

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Under IRC 7525 (a) (2), unlike the attorney-client privilege, the FAPT privilege does not apply in criminal tax matters and may only be asserted as a privilege in “noncriminal tax matter before the IRS” and in a “non-criminal tax proceeding in a Federal Court brought by or against the US”. The legal effect is that tax advice rendered has a limited attorney-client privilege only for “non-criminal tax matters”.

The FAPT privilege only applies to communications made on or after 7/22/98. The privilege does not apply to any written communication before 10/22/04 between a FAPT and a director, shareholder, officer, employee, agent, or representative of a corporation in connection with the promotion or the direct or indirect participation of such corporation in any tax shelter (the term tax shelter is defined in 26 USC Sec. 6662 (d) (2) (C).

IRC Sec. 7525 was amended by the American Jobs Creation Act of 2004, so that the privilege does not apply to written communications made on or after 10/22/04, involving a federally authorized tax practitioner with respect to the participation of any person (not just a corporation) in a tax shelter (Pu. L. No. 108-357).

The FAPT privilege applies only to tax advice not general business consultations or personal financial planning advice. The tax advice must be treated as confidential to be covered by the privilege. If the communication is divulged to 3rd parties, then, it is not confidential.

Current case law indicates that a communication in connection with tax return preparation is not covered or protected by the FAPT privilege. In US v. Gurtner (474 F.2d 297 (9th Cir. 1973) the US 9th Cir. Ct. of Appeals held that tax return preparation does not involve giving or receiving legal advice. In US v. Cote (456 F.2d 142 (8th Cir. 1972), the US 8th Cir Ct. of Appeals held that tax returns are not privilege based on the rationale that tax returns are intended for disclosure to a 3rd party (IRS) so there can be no expectation of confidentiality which defeats the claim that the tax return or pertinent communication is privileged.

Regarding the the rules of confidentiality of tax returns and tax return information held by the IRS or tax practitioner (IRC Sec. 6103, 7213, 7213A, 7216) the confidentiality protections in those rules do not render the communication confidential for purposes of the FAPT privilege.

Offshore Accounts

Tax Advisors (Attorneys/CPAs) who render tax advice to a taxpayer for offshore accounts (or other tax matters) may have no attorney-client privilege and may themselves be subject to criminal penalties.

US Taxpayers with undisclosed offshore accounts face a myriad of civil and criminal tax penalties. In addition, the Taxpayer may not have the attorney-client privilege for confidential communications if the professional services from legal counsel was for tax advice and the IRS investigates taxpayer for criminal tax evasion.

Under IRC Sec. 7525 (effective date 7/22/98), there is no attorney-client privilege for tax advice rendered if the IRS pursues a criminal tax investigation. The implications for the US Taxpayer and advisors include the following:

  1. US Taxpayers with undisclosed offshore accounts and/or unreported income (from offshore or domestic accounts) may not be able to assert an attorney-client privilege if questioned by the IRS;
  2. Their tax advisor (ie. Attorney or CPA), who rendered tax advice to them, may be unable to refuse to answer IRS inquiries or produce Taxpayer records;
  3. Under 18 USC Sec. 371(conspiracy to commit tax evasion) when 2 or more parties collude to evade taxes due they may be held liable for a criminal tax conspiracy and face felony charges (5 years in jail), known as a “Klein conspiracy”;
  4. Under Treasury Dept. Circular #230 (the rules governing tax practice before the IRS), Sec 10.21 requires a tax practitioner, who is aware that a taxpayer is non-compliant with federal tax law to advise the taxpayer of both the taxpayer tax non-compliance and the penalties for continued tax non-compliance, or the tax practitioner faces suspension or disbarment for their tax practice before the IRS.
  5. Under 18 USC Sec. 4, Misprision of a Felony: “Whoever has knowledge of actual commission of a felony…. must refer the matter to a judge or other civil or military authority… or is subject to “be fined, or imprisoned not more than 3 years or both (effective 6/25/48).

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The term “tax advice” means advice given by an individual with respect to a matter that is within the scope of an individual’s authority to practice (IRC Sec. 7525 (a) (3) (B). Under IRC Sec. 7525 (a)(1): “with respect to tax advice, the same common law protections of confidentiality, which apply to a communication between a taxpayer and an attorney, shall also apply to a communication between a taxpayer and any federally authorized tax practitioner (“FAPT”), to the extent the communication would be considered a privileged communication if it were between a taxpayer and an attorney”.

A FAPT (federally authorized tax practitioner) means an individual authorized under federal tax law to practice before the IRS where the practice is subject to federal regulation under 31 USC Sec. 330 (IRC Sec. 7525 (a)(3)(A). The term FAPT includes an attorney, CPA, an enrolled agent, or an enrolled actuary. The FAPT does not apply to accountants who are not CPAs (unless the accountant qualifies as an enrolled agent). See Treasury Dept Circular 230, IRS Pub 947).

Under IRC 7525 (a) (2), unlike the attorney-client privilege, the FAPT privilege does not apply in criminal tax matters and may only be asserted as a privilege in “noncriminal tax matter before the IRS” and in a “non-criminal tax proceeding in a Federal Court brought by or against the US”. The legal effect is that tax advice rendered has a limited attorney-client privilege only for “non-criminal tax matters”.

The FAPT privilege only applies to communications made on or after 7/22/98. The privilege does not apply to any written communication before 10/22/04 between a FAPT and a director, shareholder, officer, employee, agent, or representative of a corporation in connection with the promotion or the direct or indirect participation of such corporation in any tax shelter (the term tax shelter is defined in 26 USC Sec. 6662 (d) (2) (C).

IRC Sec. 7525 was amended by the American Jobs Creation Act of 2004, so that the privilege does not apply to written communications made on or after 10/22/04, involving a federally authorized tax practitioner with respect to the participation of any person (not just a corporation) in a tax shelter (Pu. L. No. 108-357).

The FAPT privilege applies only to tax advice not general business consultations or personal financial planning advice. The tax advice must be treated as confidential to be covered by the privilege. If the communication is divulged to 3rd parties, then, it is not confidential.

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Current case law indicates that a communication in connection with tax return preparation is not covered or protected by the FAPT privilege. In US v. Gurtner (474 F.2d 297 (9th Cir. 1973) the US 9th Cir. Ct. of Appeals held that tax return preparation does not involve giving or receiving legal advice. In US v. Cote (456 F.2d 142 (8th Cir. 1972), the US 8th Cir Ct. of Appeals held that tax returns are not privilege based on the rationale that tax returns are intended for disclosure to a 3rd party (IRS) so there can be no expectation of confidentiality which defeats the claim that the tax return or pertinent communication is privileged.

Regarding the the rules of confidentiality of tax returns and tax return information held by the IRS or tax practitioner (IRC Sec. 6103, 7213, 7213A, 7216) the confidentiality protections in those rules do not render the communication confidential for purposes of the FAPT privilege.

Willfulness

Under the IRS rules, the willfulness element essential for a criminal tax evasion charge is defined as follows: (see IRS Criminal Tax Division/Office of Chief Counsel Tax Crimes Handbook)

“Willfulness is the voluntary, intentional violation of a known, legal duty: See: Cheek v. US 498 US 192, 200-201 (1991); US v. Pomponio 429 US 10,12 (1976); US v. Bishop 412 US 346, 360 (1973).

The subjective test is “A defendants’ good faith belief that he is not violating the tax law, no matter how objectively unreasonable that belief may be, is a DEFENSE IN A TAX PROSECUTION. See Cheek, supra.

Mental impairment can be a defense subject to a medical evaluation which may include; loss of memory from drug/alcohol addition, brain impairment from personal injury (e.g.. car accident), or disease (Alzheimer’s disease affected over 5m US people of all ages in 2015).

The key issue is whether there was a mental impairment at the time a tax crime was committed e.g. failure to declare an offshore account, failure to report income and other tax crimes.

For a U.S. taxpayer to avoid criminal prosecution, the tax rules are different than those tax rules for imposition of civil penalties. Tax crimes require “intent”; i.e. the U.S. taxpayer deliberately and intentionally pursued a criminal course of conduct.

The U.S. taxpayer must demonstrate that he had “a good faith belief” that he did not owe tax. If so, the U.S. taxpayer may be able to prevent a criminal conviction but not necessarily prevent being criminally prosecuted. The U.S. taxpayer must demonstrate that their “tax theory” (however misguided) was in “good faith” in order to negate the “intent element” of the crime of tax evasion.

For example, in the case of Vernice Kuglin, she successfully convinced a jury that the IRS’s failure to respond to her written inquiry regarding the need to file a tax return or pay tax on over $900,000 in U.S. taxable income was a “reasonable, good faith belief” and she was not convicted of tax evasion.

For example, in the 2007 case of Tom Cryer (an attorney in Louisiana) tax evasion charges were dropped and he was acquitted on charges of willfully failing to file a tax return. Cryer’s defense was that the IRS refused to respond to his repeated demand that the government explain why his “tax theories” were not viable, instead they refused to respond to Cryer, stating his tax positions were “frivolous”.

At trial, Cryer convinced jurors that he genuinely believed he owed no tax for the years in question, and without proof of criminal intent, he was acquitted.

In the case of the actor Wesley Snipes, he provided the IRS with a 600-page explanation of why he was a “non-taxpayer” which the IRS ignored as a “tax protester” manifesto. He was not convicted of tax evasion (i.e. a felony) but was convicted for failure to file a tax return (misdemeanor) and was sentenced to three one-year consecutive prison terms.

For civil tax penalties, U.S. taxpayers must demonstrate the key element for a penalty defense; i.e. reasonable reliance on counsel. In criminal courts, reliance on counsel is essential but the courts give wide latitude with respect to a willfulness defense and the taxpayer’s “good faith belief”.

In criminal cases, the prosecutor must prove beyond a reasonable doubt willfulness, or specific criminal intent, which means that the defendant:

  1. Knew and understood the law; and
  2. Intentionally set out to violate it; i.e. had the purpose of evading assessment or collection of taxes.

Regarding willfulness, the defendant may present a good faith defense, including good faith belief and reliance when reliance includes all that the defendant read and heard. According to the U.S. Supreme Court, good faith is a defense, no matter what the belief. However, the defendant is not allowed willful blindness; i.e. the defendant intentionally concealed the truth from himself.

Criminal penalties may be imposed for intentionally violating federal tax laws (i.e. willful violation). “Ignorance of the law excuses no one” is a legal principle holding that a person who is unaware of a law may not escape liability for violating that law merely because he or she is or was unaware of its content.

Under U.S. Model Penal Code Sec. 2.02(9), knowledge that at an activity is unlawful is not an element of an offense unless the statute creating the offense specifically makes it one.

In Cheek v. U.S. (1991), 498 U.S. 192, willfulness is required for federal tax crimes. In Cheek, the U.S. Supreme court reversed his conviction for willful failure to file a tax return.

Cheek’s “tax theory” was that wages did not constitute income and he therefore failed to file a tax return. The U.S. Supreme Court held that Cheek was entitled to a good faith instruction to the jury; i.e. the jurors could acquit him if they found Cheek believed in good faith that he was not required to file. The prosecutor had to prove that Cheek did not rely in good faith on what he heard and read. Cheek was eventually convicted and served a year and a day.

In order to avoid criminal convictions, U.S. taxpayers must rely upon independent, competent counsel. In the case of U.S. v. Lindsey Springer, (Case No. 09 C.R. 043 JHP, Northern District of Oklahoma), the taxpayer and his attorney each received a 15 year sentence for conspiracy to defraud the U.S. and evasion of taxpayer’s taxes by use of the attorney’s trust account to funnel client funds and from which account client expenses were paid.

Although the good faith belief and reliance arguments may be usable as a defense in a criminal tax case, often these off-shore situations involve “money laundering” (i.e. disguising the nature or origin of the funds), in which the government may criminally prosecute under the principal of “intentional blindness” or “ignoring what is reasonable” as a basis for conviction.

The best defense is a specific tax opinion letter from an independent, competent tax professional.

Under Mortensen v. Commr., 440 F.3d 375, 385 (6th Cir. 2006), it was held that reasonable minds can differ over tax reporting, and under tax audits the IRS may disallow certain transactions.

The U.S. Congress was concerned that taxpayers would participate in the “audit lottery” and take questionable positions on their tax returns in the expectation of not being audited (See: H.R. Rep. No. 101-247, 1388 (1989). H.R. Rep. No. 101-247, as reprinted in 1989 U.S.C.C.A.N. 1906, 2858.

IRC Sec. 6662(b) imposes a civil penalty for substantial understatements of income, or liability overstatements (in addition, other civil penalties may be imposed for negligence and substantial valuation misstatements).

Under IRC Sec. 6064(c), no penalty will be imposed with “respect to any portion of an underpayment if it is shown that there was reasonable cause and the taxpayer acted in good faith.”

Under Treasury Regulation Section 1.6664-4(b)(1), “reasonable cause” and “good faith” require courts to review the following taxpayer issues:

  1. Experience;
  2. Knowledge;
  3. Sophistication;
  4. Education;
  5. Taxpayer reliance on a tax professional; and
  6. Taxpayer’s effort to assess the taxpayer’s proper tax liability.

Under Treas. Reg. Sec. 1.6664-4(c), the IRS minimum requirements for determining whether a taxpayer reasonably relied in good faith on advice including a tax advisor’s professional opinion.

The minimum requirements include:

  1. The advice must be based on all pertinent facts and circumstances and the law as it relates to those facts and circumstances;
  2. The advice must not be based on unreasonable factual or legal assumptions;
  3. The advice must not unreasonably rely on the representations, statements, findings or agreements of the taxpayer or any other person;
  4. A taxpayer may not rely on an opinion or advice that a regulation is invalid to establish that the taxpayer acted with reasonable cause and good faith unless the taxpayer adequately disclosed that the regulation in question is invalid (Treas. Reg. Sec. 1.6662-3(c)(2).

Under Treasury Regulation Sec. 1-6664-4(b)(1), reasonable cause and good faith are not necessarily established by reliance on the advice of a professional tax advisor.

However, under Treas. Rg. Sec. 1.6664-4(b)(2), a taxpayer may satisfy the “reasonable cause” and “good faith” exception because the taxpayer believed that the tax professional had knowledge in the relevant aspects of federal tax law.

In United States v. Boyle, 469 U.S. 241, 251 (1985), the U.S. Supreme Court held:

  1. Taxpayers may not be sophisticated in tax matters, and that it is unrealistic for taxpayers to recognize errors in the substantive advice of an accountant or attorney;
  2. To require the taxpayer to challenge the attorney, to seek a second opinion, or to try to monitor counsel would nullify the purpose of seeking the advice of a presumed expert in the first place.

Under Sklar, Greenstein & Scheer, P.C. v. Commr., 113 T.C. 135, 144-145 (1999) citing Ellwest Stereo Theaters of Memphis, Inc. v. Commr., T.C.M. 1995-610, the Tax Court established a three-prong test to prove reasonable cause, where a taxpayer is asserting a defense against an IRC Sec. 6662 penalty:

  1. The tax advisor was a competent professional who had sufficient expertise for justifying reliance;
  2. The taxpayer provided necessary and accurate information to the advisor;
  3. The taxpayer actually relied in good faith on the advisor’s judgment.

Under Treas. Reg. Sec.1-6664-4(b)(1), reliance on a tax advisor may be considered reasonable when the taxpayer knew that the tax advisor possessed specialized knowledge in the relevant aspects of federal tax law.

In the case Neonatology Assoc., P.A. v. Commr., 115 T.C. 43, 99 (2000), aff’d 299 F.3d 211 (3d Cir. 2002) the court held:

  1. Taxpayer reliance on an insurance agent was found to be unreasonable because the insurance agent was not a tax professional;
  2. The taxpayers were sophisticated and should have known that the tax benefits discussed were “too good to be true’;
  3. The court rejected the evidence the taxpayers presented that they also relied on tax attorneys and accountants.

In Stanford v. Commr., 152 F3d 450 (5th Cir. 1998) the court held:

  1. Taxpayer could rely on a CPA with extensive experience in international banking law for advice regarding the taxpayer’s controlled foreign corporation.
  2. It was not reasonable to expect the couple to monitor their CPA to make sure he conducted sufficient research to give knowledgeable advice.
  3. Intelligent investors have independent educated experts to advise them, particularly with respect to arcane matters of the law.
  4. The Court vacated the penalty since the CPA was diligent in reviewing the taxpayer’s business and tax records, and studying the statute, legislative history and regulations.

In Larson v. Commr., TC Memo 2002-295, 84 T.C.M. 608 (2002), the Court held that to satisfy the “reasonable cause” and “good faith” exception, the taxpayer must provide necessary and accurate information to the tax advisor. In Larson, the taxpayer received an incorrect Form 1099 which due to a printing error, read $1,891 (not $21,891). Here, the ”reasonable cause” and “good faith” exception did not apply since the taxpayer had reason to believe that the tax reported on the tax return was not accurate and the taxpayer should have made additional efforts to assess the proper amount of his tax liability.

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In Woodson v. Commr., 136 T.C. 585 (2001), the court held that the taxpayer’s reliance on a return preparer did not constitute reasonable cause, since to qualify for the “reasonable cause penalty exception” the taxpayer must rely in good faith on the tax advisor’s judgment or advice.

In Woodson, the tax return failed to include a $3.4M tax item and substantially understated the tax liability, the result of a “clerical mistake”. Here the court did not apply the reasonable cause exception because the tax professionals did not provide advice to the taxpayers.

Under Treas. Reg. Sec. 1-6664-4(c)(2), tax advice constitutes analysis on the conclusions of a professional tax advisor. Here, the taxpayers did not provide evidence to show that a professional tax advisor’s analysis or conclusions led to the omission of the item on the tax return. The taxpayers were not able to satisfy the “reasonable cause” and “good faith” defense as the taxpayers did not review the proposed return to ensure that the income items were included.

In Thomas v. UBS, 7th Cir. (2013), the court held that the Swiss Bank, UBS, is not liable to U.S. account owners for fines and interest paid when confessing to the IRS about their foreign accounts. The U.S. accountholders sued UBS, claiming the bank didn’t give them accurate tax advice and should have kept them from breaking the law. The court threw out their lawsuit, saying they were tax cheats who didn’t merit a day in court.

In Canal Corp. v. Commr., 135 T.C. 199 (2010), the court held that taxpayers may defend against the “accuracy-related” penalty, when the taxpayers rely on a tax professional, under a “three-prong test”:

  1. The taxpayer provided necessary and accurate information to the advisor.
  2. The taxpayer acted in good faith on the tax professional’s advice.
  3. The tax advisor had apparent expertise to justify reliance.

In Canal the test was not satisfied and the court imposed accuracy-related penalties despite the taxpayer’s reliance on a sophisticated advisor.

Taxpayers must not rely on tax professionals that provide tax advice that they personally know is incorrect or that they believe might not be correct based on their previous experience or business knowledge. Additionally, taxpayers should review any Form 1099s or other informational returns they receive to ensure they are complete and accurate.

In the case of U.S. v. Williams (U.S. App. Lexis 15017), (4th Cir. Va., July 20, 2012) (unpublished)), the 4th Circuit reviewed a District Court judgment that for civil penalty purposes Williams did not willfully fail to report his interest in two foreign bank accounts under 31 U.S.C. 5314.

The court held that Williams’ conduct constituted “willful blindness” since:

  1. He chose not to report the income;
  2. He knew he had an obligation to report the existence of the Swiss accounts;
  3. He knew what he was doing was wrong and unlawful;
  4. On his Form 1040 tax return, he “checked no” on Schedule B regarding having an interest in foreign accounts.

The 4th Circuit ruled that Williams willfully violated 31 U.S.C. Sec. 5314 (to report two foreign bank accounts).

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Civil Penalties (Tax Advice)

A U.S. taxpayer who relies on the advice of a tax professional may relieve the U.S. taxpayer from civil penalties if there has been no willful neglect. Under the IRC Sec. 6664: “No penalty shall be imposed… with respect to any portion of an underpayment if it is shown that there was a reasonable cause for such portion and the taxpayer acted in good faith with respect to such portion “. Under related Treasury Regulations: “Reliance on an information return, professional advice, or other facts constitutes reasonable cause and good faith if under all the circumstances, such reliance was reasonable and the taxpayer acted in good faith.”

Under IRS Circular No. 230, U.S. taxpayers may now rely on tax opinions for relief from penalties only, if:

  1. The tax opinion is based on a full legal and factual review and covers all the issues;
  2. The drafter of the tax opinion may not be involved directly or indirectly with the “tax-shelter” promoter; i.e., it must be an independent tax opinion.

In the case of Canal Corp. v. Commr.,135 T.C. 199 (2010), the court held that the taxpayer could not rely upon Price Waterhouse Cooper’s (PWC) tax opinion (for which they paid $800,000) because of PWC’s involvement with the “underlying structures”; i.e. the tax shelter.

A U.S. taxpayer may avoid civil penalties if the U.S. taxpayer;

  1. Makes full disclosure;
  2. To an independent tax professional;
  3. Who is experienced in the area of law;
  4. Receives, reviews and understands the advisor’s tax opinion;
  5. No “blind reliance” on the tax opinion; i.e. two tests: “You should know better”, or “It’s too good to be true”.
  6. The taxpayer must rely upon the opinion; and
  7. The taxpayer must follow the plan and the opinion.

About the Author:

The Wolfe Law Group represent U.S. Taxpayers for IRS Tax Audits, U.S. Investors who have International Investments, and Foreign Persons who invest in the United States. We have over 30 years of experience, specializing in IRS Tax Audits and International Tax Matters including: International Tax Planning/Tax Compliance, and International Asset Protection.

The Wolfe Law Group
Gary S. Wolfe, Esq.
6303 Wilshire Blvd., #201
Los Angeles, CA 90048
Tel: 323.782.9139
Fax: 323.782.9289
Email: gsw@gswlaw.com

 

SEE MORE:

Criminal Tax Evasion: Part 1

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