Brokerage commission benchmarking and investment advisory comparability depend on functional differences, economic circumstances and the services prov...
Undisclosed foreign assets require an asset held in the taxpayer's name or beneficially owned by the taxpayer, with an unexplained or unsatisfactorily explained source of investment. Nominee shareholding or signing authority does not by itself establish beneficial ownership of company funds, as a company is legally distinct from its shareholders. Affidavits supported by contemporaneous records cannot be discarded on conjecture when they are neither disproved by cogent evidence nor tested through cross-examination. The year-of-discovery rule does not displace the statutory conditions for an undisclosed asset. Consequential penalties cannot survive deletion of the underlying additions.
Undisclosed foreign assets require an asset held in the taxpayer's name or beneficially owned by the taxpayer, with an unexplained or unsatisfactorily explained source of investment. Nominee shareholding or signing authority does not by itself establish beneficial ownership of company funds, as a company is legally distinct from its shareholders. Affidavits supported by contemporaneous records cannot be discarded on conjecture when they are neither disproved by cogent evidence nor tested through cross-examination. The year-of-discovery rule does not displace the statutory conditions for an undisclosed asset. Consequential penalties cannot survive deletion of the underlying additions.
Note: It is a system-generated summary and is for quick reference only.
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