by Brian Mahany
Albert and Mary Anne Berrettini are spending some time as guests of the United States. More on that later. Back in the 90’s, the Berrettinis got hooked up with Tower Executive Resources. That company “helped” Americans evade taxes by parking unreported income in offshore accounts, often at Barclays Bank in the Turks. To further frustrate proper assessment of tax and conceal the transfers, Tower created false invoices for “lease” payments. This allowed clients to show the money going to Tower as a deductible business expense.
Clients that wanted to access their money could get their money back through a debit card or in the case of the Berrettinis, through false loans. They acted as if they were borrowing money from a Tower affiliate when they were really just repatriating their own money.
Like many of these scams, Tower collapsed and in its wake the government accessed its list of clients. For the Berrenntinis, that ultimately meant criminal prosecution. Defiant to the end, the Berrenntinis took the case to trial and lost. I say defiant because Albert has accused the court of treason and sedition. Strong words.
Albert is serving a sentence of 27 months, his wife Mary Anne is on a two year probation. Still not happy, Albert appealed. That appeal was quickly shot down as well.
The lesson here is that by participating in heavily marketed tax avoidance schemes, your risk of getting caught goes up exponentially. It’s one thing to quietly park money offshore and hope you don’t get caught. But when you join a group or movement, expect the government knows of it and will ultimately get the member list. Ditto for parking your money in a well known bank – if bank secrecy isn’t dead yet, its certainly bleeding profusely.
Although reading tax freedom movement literature is not a crime (I read it), following bad advice can be a crime.
For the record, we do not advocate tax evasion in any stripe or flavor. Whatever your views on the Constitutionality of our tax laws, the courts have the final say. If a promoter tells you otherwise, beware.
If you have unreported offshore income and assets, there is a small window to avoid onerous penalties (offshore voluntary disclosure initiative or “offshore amnesty”) but that window closes in August. If you have other tax compliance issues, we can help too. For a no obligation and confidential consultation, call attorney Brian Mahany. Brian can be reached at (414) 704-6731 (direct) or by email at
Mahany & Ertl – America’s tax lawyers. Offices in Milwaukee, Wisconsin; Detroit, Michigan & Portland, Maine. Services nationwide.