Writings by Frank L. Brunetti

Frank Brunetti has been practicing law for over thirty years in the areas of estate and wealth preservation, tax planning for business entities and complex tax matters. He is admitted to the New Jersey and New York Bars as well as the United States Tax Court.

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The Plight of Billionaires Looking For New Havens to Shield Assets

In a recent article in Wealth Management, the author David de Jong and Robert Lafranco describe the difficulty billionaires face in providing a safe haven to shield assets. For example, they point out the troubles of Dimitry Rybolovelev who is Russia’s 14th richest person and is embroiled in a multi-jurisdiction divorce action with his wife. […]

Author: Frank L. Brunetti

July 30, 2013

Treasury, IRS Delay FATCA Withholding Provision

Financial institutions around the world will have more time to comply with the Foreign Account Tax Compliance Act (FATCA) as the Internal Revenue Service and Treasury Department will delay implementation of the withholding provision until July 1, 2014. The agencies said high interest in the program from financial institutions prompted it to delay the program by six […]

Author: Frank L. Brunetti

July 24, 2013

Offshore Tax Evasion

IRS Embattled with Technology Firms Over 2004 Corporate Tax Holiday

The Internal Revenue Service is taking a closer examination of corporations’ tax strategies during the 2004 tax holiday, and two technology firms in particular have drawn scrutiny from the federal agency. In two separate tax law cases, the IRS is battling BMC Software Inc. and Analog Devices, both of which are citing a 2004 corporate […]

Author: Frank L. Brunetti

July 19, 2013

Pohlad Estate Brings Lawsuit Against IRS Over $189 Million Tax Bill Regarding Minnesota Twins

Robert and William Pohlad, sons of late Minnesota Twins owner Carl Pohlad, who passed away in 2009, have brought a lawsuit against IRS regarding a disputed $189 million tax bill. The IRS recently imposed the multi million-dollar tax liability on the heirs, arguing that Pohlad’s estate undervalued his stake in the Minnesota Twins, according to Forbes. In […]

Author: Frank L. Brunetti

July 15, 2013

DOMA Ruling May Have Estate Tax Planning Implications

The U.S. Supreme Court’s landmark ruling that the Defense Against Marriage Act (DOMA) is unconstitutional will have far-reaching benefits that change the paradigm of health benefits enrollment, retirement benefits, and tax planning. Regarding the latter, same-sex married couples may see sweeping changes to their estate tax planning and gift tax rules. Under current tax rules, […]

Author: Frank L. Brunetti

July 12, 2013

Global Tax Evasion Compliance Deadline Nears

In one of the largest coordinated global tax evasion strategies in history, the United States is on pace to open up registration to foreign financial firms that service U.S. clients on July 15, 2013. The financial industry continues to lobby for more time and the Internal Revenue Service has not yet released registration procedures and […]

Author: Frank L. Brunetti

July 11, 2013

Tax Law Violations

Gifts Should be a Crucial Part of Your Business Succession Plan

Many small business owners want to keep their legacy intact by passing down their companies to family members. Many small business owners want to keep their legacy intact by passing down their companies to family members. A viable succession plan is essential for these owners in not only passing down assets, but also doing so […]

Author: Frank L. Brunetti

July 10, 2013

Gift Tax

ICIJ Publicly Releases New Offshore Tax Haven Report

The Internal Revenue Service, lawmakers and Americans began paying more attention to the International Consortium of Investigative Journalists following its public release of hundreds of names and financial details of offshore account holders in April. Now, the ICIJ has released a new report, which gives the public access to extensive offshore tax haven records through its new […]

Author: Frank L. Brunetti

July 1, 2013

Tax Evasion Tops List of Priorities at G-8 Summit

The Internal Revenue Service’s recent crackdown on tax evasion and fraud may have initially appeared to be an American phenomenon, but tax law violations appear to be an international issue. As the leaders of the international community meet for the upcoming G-8 summit, tax issues and combating tax evasion are expected to top the list […]

Author: Frank L. Brunetti

June 28, 2013

IRS Seeks $100 Million from Former HP Chairman Ray Lane

Ray Lane, former chairman of Hewlett-Packard Co., and the Internal Revenue Service remain at odds over a reported $100 million tax bill which Lane plans to dispute. The businessman said he will appeal a ruling by the U.S. Tax Court which claims he owes roughly $100 million in taxes as a result of his participation […]

Author: Frank L. Brunetti

June 24, 2013

IRS to Hammer Down on Bitcoins, a Virtual Currency

The Internal Revenue Service is increasing its focus on tax law compliance, as evidenced by the recent crackdown on offshore tax evasion and international financial-account sharing agreements with popular tax havens. However, the IRS is zeroing in on a new potential gateway for tax evasion that may affect taxpayers of all income levels: virtual currency. […]

Author: Frank L. Brunetti

June 21, 2013

Small Businesses May Be Subject to IRS Robo-Audits

The Internal Revenue Service is leaning more heavily on technology to help detect potential tax law violations, and this trend is expected to continue as it faces limited manpower to execute compliance protocols and audits. Historically, the IRS has used so-called “robo-audits” to monitor inconsistencies in the tax returns of middle-income Americans. However, a recent […]

Author: Frank L. Brunetti

June 17, 2013

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