Tag: richard s lehman

IC-DISC and United States Exporting of Computer Software, Internet Sales and Licenses

The Technical Advice Memorandum reviewed the term “export property” for DISC purposes in depth and determined in its holding that computer software could indeed be “export property”.

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Taxation of the Clawback in a Ponzi Scheme

VIDEO: Taxation of the Clawback in a Ponzi Scheme – Maximum Tax Recovery Total presentation time: 01:32:07 by Richard S. Lehman, Esq. This article unfolds in an interesting fashion. Every item we cover in this article is a building block

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The Concept Of Willfulness, In The Eyes Of The IRS, by Richard S. Lehman, Esq.

In tax law “willfulness” has its own definition and it is an important definition for every taxpayer. That is because a taxpayer who “willfully” filed or did not file accurate tax information can be subjected to numerous very expensive penalties

Posted in Domestic Taxation, IRS Amnesty, OVDP, Bank Deposits, Foreign Assets, Streamlined Compliance, Settling with the IRS Tagged with: , , ,

The United States Tax Benefits Of Exporting

Thus the magic of the IC-DISC is to provide both tax deferral and to apply a 15% maximum dividend tax rate to profits that would otherwise be taxable in the U.S. taxpayer’s highest brackets that can range as high as 50% . . .

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Favorable Tax Consequences – Ponzi Schemes And The Clawback

What is less familiar is the fact that an investor in a Ponzi Scheme cannot only lose all of their investment. Investors in Ponzi Schemes can also be forced to pay back additional moneys earned from the Ponzi Scheme years before it exploded. This is what is known as a clawback.

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Tax planning for the non-resident alien immigrating to the United States

The immigrating Non Resident Alien must prepare for a tax life as a Resident Alien. This means taking advantage of all of the tax deductions and tax investment incentives offered by the U.S. Tax Code. It may actually mean leaving certain of the taxpayer’s foreign investments in place. This is also the subject of a separate article on the Taxation of Immigrating to the United States.

Posted in Pre-immigration income tax planning, United States Taxation of Foreign Investors Tagged with: , ,

Just Announced – FREE U.S. TAX LAW Seminars

NEW U.S. TAX LAW Seminar Series: 5.5 hours FREE Continuing Education Course Credits These seminars cover a complete range of topics dealing with legal and practical advice for foreign investors that invest in United States businesses, United States real estate

Posted in Domestic Taxation, Ponzi Scheme, Clawback, Refund of Losses, Settling with the IRS, United States Taxation of Foreign Investors Tagged with: , , , , , , , , ,

Making The Offer In Compromise – Simple

Offer in Compromise settlements are based upon the Taxpayer’s assets and overall financial situation. The worse the Taxpayer’s financial situation looks, the better the settlement with the I.R.S. The bad economy is one reason why now is the time to consider an Offer in Compromise.

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The Tax Consequences of the “Clawbacks” In Madoff and Other Ponzi Schemes

The use of Code Section 1341 can increase tax refunds and interest payments by 100% and more.

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Business survival can depend on protected investments

By Richard S. Lehman, Tax Attorney In last week’s column, we established that today’s business climate is extremely treacherous for all sizes and types of business. Whether a suit is won or lost, frivolous or legitimate , there are major

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