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Question:
"Criminal Fraud versus Civil Fraud and Taxation of U.S. Businesses Operating Abroad" Please respond to the following:
Imagine a situation in which a client under audit by the IRS omitted $100,000 in income. From the e-Activity, examine the major factors relative to the omission by the client that would result in a criminal investigation, rather than a civil fraud proposal by the IRS.
Per the text, a U.S. parent company does not include the income of a foreign subsidiary until the income is repatriated as dividends. Defend the creation of foreign subsidiaries as a mechanism to defer income of major U.S. companies. Propose a new tax law that will benefit the U.S.
Treasury from the deferral of income from foreign subsidiaries and encourage the repatriation of the previously deferred income.
Verified Expert
This paper states the factor relative to the omission by the client that would result in a criminal investigation, rather than a civil fraud proposal by the IRS when audit commenced by IRS and tax law that would the U.S. Treasury from the deferral of income from foreign subsidiaries.
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