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DAVID CORKER and ELLEN ZEISLER warn that a minor connection with the US can result in major consequences if a tax mitigation scheme goes wrong.
DAVID CORKER and ELLEN ZEISLER warn that a minor connection with the US can result in major consequences if a tax mitigation scheme goes wrong.
THOSE WHO ADVISE upon and benefit from creative tax mitigation schemes know there is no clear line of demarcation between tax avoidance and mitigation. There is always a risk that a tax collection authority will claim that a scheme amounts to a tax fraud. Some recent developments in the US and the UK serve to accentuate that risk. The subject of this article is to narrate these developments and explain how they increase the risk of criminal problems later on.
United States
Whereas in the UK tax delinquency is regarded primarily as a subject for administrative and regulatory law in the United States it is seen far more as criminal conduct. From Al Capone onwards prosecutions for tax fraud have been regarded...
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