In SHOCKLEY v. COMM., the Court of Appeals for the Eleventh Circuit, reversed the Tax Court, and held that a Tax Court petition filed by former shareholder-officers of a corporation qualified as a “proceeding in respect of” the corporation's multimillion dollar deficiency that suspended the statute of limitations under Code Sec. 6503(a)(1). Accordingly, the notices…
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4th DCA Reverses DC – Intent to Evade Taxes Does Not Makes sequent Violations of FBAR Rules Willful – Willful Blindness Does.
United States v. J.Bryan Williams; No. 10-2230 Decided: July 20, 2012 Reversed by unpublished opinion. Judge Shedd wrote the majority opinion, in which Judge Motzconcurred. Judge Agee wrote a dissenting opinion. Unpublished opinions are not binding precedent in this circuit. The parties agree that Williams violated § 5314 by failing to timely file an FBAR for…
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Use of Barbodos for Mexican Tax Planning
The removal of Barbados from Mexico’s blacklist of tax havens is a pivotal landmark. Now Mexican residents have secure and reliable alternatives for outbound investments through the use of Barbados entities. Using Barbados as a platform, this new development provides excellent tax planning opportunities for Mexican clients. For more information on how Barbados may be…
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Super-rich 'hiding' at least $21tn in Tax havens
A new study for the lobbying group Tax Justice Network (TJN) claims that wealthy individuals worldwide are holding between USD21 trillion and USD32 trillion in bank accounts in low-tax international financial centres. The research was compiled by James Henry, formerly chief economist at the management consultancy McKinsey. He used data published by the Bank of…
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