Hale Stewart, Tax Advisor

Over the last few months, I’ve documented a series of cases where courts forced grantors of a foreign asset protection trusts to disgorge assets despite placing this fund into a “bulletproof” offshore structure. Those who continue using FAPTs offer the following rebuttals to the case law.Over the last few months, I’ve documented a series of cases where courts forced grantors of a foreign asset protection trusts to disgorge assets despite placing this fund into a “bulletproof” offshore structure. Those who continue using FAPTs offer the following rebuttals to the case law.

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Hale Stewart, Tax Advisor

This is the fifth entry in my series on foreign asset protection trust failures. It shares a number of facts with the other cases. These are:

  • A less than savory character. Bilzerian was convicted of securities fraud.
  • A lengthy legal process. This August 2000 decision was the last in a series of hearings and trials that started in the early 1990s.
  • An offshore asset protection scheme: The taxpayer had a Cook Island trust.
  • Fraudulent Transfer issues: Bilzerian established and funded the trust during the trial.
  • The taxpayer argued the court couldn’t hold him in contempt because it was impossible to comply with the court’s disgorgement order.

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