Commentary Omnibus.2017.09.25: PWC Launches Law Firm, New Wealthiest Woman in World; New FBAR Willful Failure Decision; When Sharia & US Tax Law Collide

  • PWC to Launch Law Firm.   Big Four firm PwC is launching an independent law firm in the U.S., according to published reports. The unit, which will be called ILC Legal, will be a separate entity from the firm, and will not offer advice on U.S. law, according to, but will work with U.S. clients on international legal issues, such as international corporate structuring, M&A, immigration, and tax controversy.
  • Taxpayer found to not have willfully filed erroneous FBAR.   For the IRS the case of Bedrosian v. United States, US DC ED Pa, Case No. 2:15-cv-05853 was ultimately a loss—but the Court did agree that the test for “willfulness” for failing to file a Federal Bank Account Reporting (FBAR) form is whether he “knowingly or recklessly” failed to file the report (the general civil standards for willfulness) rather than whether there was a voluntary, intentional violation of a known legal duty. The court just found the IRS failed to show that the deficiencies in filing his 2007 return was done knowingly or recklessly.
  • A L’Oreal Heiress Is Now the World’s Richest Woman.
  • ‘Catch Me if You Can’ Scam Artist Has a Warning for Today’s Consumers, The Wall Street Journal.  Frank Abagnale Jr., whose exploits inspired the Leonardo DiCaprio movie, says digital technology and social media only make things easier for swindlers now.
  • When Sharia Law And The U.S. Tax Law Collide. Virginia La Torre Jeker, When Sharia and U.S. Tax Law Collide, 87 Tax Notes Int’l 787 (Aug. 21, 2017): Sharia law impacts the US tax analysis of transactions arising in any Muslim-majority country or in any country when Muslim persons are involved in the transaction. Neither the US courts nor…

Posted by Lewis J. Saret, Co-General Editor, Wealth Strategies Journal.

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