The Jackson 5 comprised of five members of the Jackson family gained renowned success when they debuted with four consecutive number ones on the chart in the 1970s.

To combat global tax evasion, the joint chiefs of tax enforcement known as the J5 have been created. The J5 is comprised of five tax authorities comprised of the Netherlands United Kingdom, Australia, Canada, and the USA criminal Enforcement division.

One cannot deny there is the connection between the Original J5 and the J5 tax enforcer if one links the lines of the Jackson greatest hit “I'll be three”. In verse one they sing. “You and I must make a pack - we will bring salvation back” seems consistent with the new J5 approach. The final verse concludes with “look over your shoulder and I'll be there.”

The question thus remains whether the new J5 can achieve the hits that the original Jackson 5. It seems recently, that the J5 enforcer came across a California burger shack owner that did not pay taxes on $350M of income. The burger entrepreneur from California, Douglas Edelman and his wife Delphine Le Dain started a burger joint in Kyrgyzstan but eventually secured $7 billion of USA government contacts during the Afghanistan war.

Mr. Edelman never filed USA tax returns or declared ownership of numerous foreign entities as he contended that his non-USA spouse was the owner of all his companies and investments.

The J5 case is built upon attribution rules which treat in this case what my wife owns is treated as owned by a husband. This appears logical especially if spouses file a joint tax return. If not a joint filing, does a husband have a right to a spouse’s fiscal data and more outrageous if living apart, separated, or a prenuptial agreement stipulated each will conduct their affairs separately. The J5 case gets a bit icy as under IRS rules there is no attribution between a US citizen and a nonresident of the USA. In Mr. Edelman case his wife is a nonresident of the USA. The J5 may fall back on the vintage argument substance over form in that his spouse is not the real owner.

In My gut the J5 case will not be to coin a lyric “as easy as A B C, as easy as 1 2 3, as simple as do ra mi.”

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