"Controlled Foreign Corporations" Please respond to the following:
- You are an IRS agent and are planning to audit a controlled foreign corporation for potential tax evasion. Suggest audit strategies that address transactions that are most likely to result in tax evasion by a controlled foreign corporation. Support your audit plan with examples.
- You are the CPA working for the controlled foreign corporation that is being audited by the IRS for potential tax evasion. Construct a defense against the audit that supports the corporation's claim that there was no tax evasion. Support your defense with examples.
"Tax Deferral" Please respond to the following:
- You are a CPA who specializes in offshore tax arrangements. A client has engaged you to develop a strategy she can use to invest abroad and defer her income from U.S. taxes. Suggest a strategy for deferring taxable income. Support your recommendation with examples.
- You have been hired by an underworld client to establish a tax haven overseas to avoid paying U.S. taxes, and avoid IRS scrutiny. Evaluate tax havens and construct a scheme that your client can use to establish a tax haven abroad and avoid IRS scrutiny. Support your scheme with examples.