- 4 -- 4 - advised Howard and petitioners regarding the purported tax benefits of offshore trusts. In 1982, with the assistance of Howard, Armstrong, and Green, petitioners established an ALA-type of offshore trust program. Five sham trusts were established and domiciled in Grand Turk, the capital of the Turks and Caicos Islands, located in the British West Indies, under the names of five shell companies (namely, DCH Management (DCH), Ledner Consulting Co. (Ledner), DARA Co. (DARA), Cosmos Investment Co. (Cosmos), and Alpha Associates (Alpha)). Bank accounts were then opened in California, one account each under the name of four of the five trusts. Howard was a trustee and an agent for Alpha, and Howard held signatory authority over the DCH, Ledner, DARA, and Cosmos bank accounts. An interest-bearing investment account was also maintained in California under Alpha’s name with the Capital Preservation Fund of the First Interstate Bank of California (the Alpha account). The Alpha account was maintained under CCMI's corporate identification number. Rachel held signatory authority over the Alpha account. Pursuant to petitioners' offshore trust program, funds transferred into the trusts represented profits realized by CCMI. During 1982 and 1983, $174,308 in profits of CCMI was transferred from CCMI through the offshore trusts and ultimately to the Alpha account. With Howard's participation, the profitsPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011