Ponzi Scheme Tax Loss

  • Total presentation time: 82:36


Veteran South Florida Tax Attorney Richard S. Lehman will explain:

  1. How to best secure a tax refund from Ponzi Scheme losses
  2. How the government has made recovery easier
  3. What you need to know about theft losses
  4. How to plan and implement a taxpayer Ponzi Scheme tax loss for maximum benefits now, and in the future.

Topics discussed in this seminar include: Ponzi schemes and theft loss, understanding the safe harbor, the theft loss, what is privity, amount of the theft loss deduction, phantom income, the year of discovery, amount of theft loss in the year of discovery, reasonable prospect of recovery, ascertainable standard, tax planning for maximum use of loss, quantifying the amount of the theft loss, the amended return, claw backs, estates and trusts, comparing safe harbor vs the law, tax planning

OCTOBER 2012 Update: The most recent Internal Revenue Service ruling allows clawback victims of Ponzi schemes to maximize their tax refunds and deduct their losses in years that would otherwise be closed by the Statute of Limitations. This is in the event the deductions are more valuable in the earlier years for purposes of tax refunds.

1. VIEW ONLINE: New I.R.S. Revenue Ruling re: clawbacks

2. RELATED ARTICLE:Favorable Tax Consequences related to Ponzi Scheme and the Clawback” this article describes completely the advantages of how to make use of Code Section 1341 noted in the new IRS ruling.

3. Report to Congress: The U.S. Government Accountability Office (GAO) Report on Customer Outcomes in the Madoff Liquidation Proceeding.


Presentation Resources

Presentation slides download as pdf

IRS Revenue Ruling: download as pdf

Revenue Procedure: download as pdf

REPORT NO.1: Bernard Madoff Tax Loss – Introduction download pdf

REPORT NO.2: A Reasonable Prospect of Recovery download pdf

REPORT NO.3: Is the Safe Harbor Worth it? download pdf

TAX MANAGEMENT Real Estate Journal Vol 27, No2, Feb 2011 Ponzi Scheme Tax Losses

Favorable Tax Consequences Related to Ponzi Schemes and the Clawback September, 2011 Read full article or download pdf

Ponzi Scheme Presentation Outline Click here to view