Answered step by step
Verified Expert Solution
Link Copied!

Question

1 Approved Answer

Taxpayer was born in France. He studied marketing in Paris. In 1990, he began working for a foreign corporation based in Switzerland that required him

Taxpayer was born in France. He studied marketing in Paris. In 1990, he began working for a foreign corporation based in Switzerland that required him to open a bank account in Switzerland. He had his paycheck deposited into the Swiss account. In 2002, he immigrated to the United States and he began his own consulting company. The consulting company provided services to clients in the United States and overseas. His US based clients made payments to him in a corporate bank account in the United States. His foreign clients made payments to his foreign bank account opened in Switzerland. From time to time, Taxpayer would transfer monies from his Swiss bank account to his American bank account. Taxpayer prepares his own tax returns. From 2002 until 2020, Taxpayer reported 100% of the income he received from his United States clients; however, he only reported as income the monies that were transferred from Switzerland to the United States for his foreign clients. Taxpayer answered no on his tax return when asked if he has a bank account outside of the United States. Taxpayer also failed to file Foreign Bank Account Reports (FBARs).

First, make the argument that Taxpayer acted willfully in not disclosing all of his foreign income and his foreign bank account. Second, make the argument that Taxpayer DID NOT act willfully. Third, you are the judge. Which argument is stronger? (40 points)

Step by Step Solution

There are 3 Steps involved in it

Step: 1

blur-text-image

Get Instant Access to Expert-Tailored Solutions

See step-by-step solutions with expert insights and AI powered tools for academic success

Step: 2

blur-text-image_2

Step: 3

blur-text-image_3

Ace Your Homework with AI

Get the answers you need in no time with our AI-driven, step-by-step assistance

Get Started

Recommended Textbook for

Accounting What The Numbers Mean

Authors: David Marshall, Wayne William McManus, Daniel Viele

7th Edition

0073011215, 9780073011219

More Books

Students also viewed these Accounting questions

Question

How did the plague contribute to the Renaissance?

Answered: 1 week ago