They own the IRS too. There is nothing in the Code that recognizes royalty payments to an offshore captive shell. Disallow the royalty payments and assess the tax! These transactions are not remotely ordinary (except among thieves) or necessary, and lack economic substance.
They own the IRS too. There is nothing in the Code that recognizes royalty payments to an offshore captive shell. Disallow the royalty payments and assess the tax! These transactions are not remotely ordinary (except among thieves) or necessary, and lack economic substance.