Attorney-at-Law

PLAY NICE AND GO INTERNATIONAL

In Uncategorized on 05/16/2022 at 15:20

Peak Potentials Training International, Docket No. 23373-18, filed 5/16/22, is back, but the IRS attorney who generated my blogpost “Play Nice or Go Home,” 3/20/20 is off the case. So now both IRS and PPTI are both playing nice.

But they need to go international. And for those of us who haven’t yet memorized Rule 81, that Obliging Jurist Judge David Gustafson shows us how it’s done, with a Request For International Judicial Assistance Letter Rogatory addressed to the Supreme Court of British Columbia, Canada.

PPTI is the US-sub of a Canadian corp. The US-sub transferred advance deposit accounts, where customers prepaid for motivational lectures, some of which might not be delivered for two years, to a US LLC. The US-sub claims a deduction for the elimination of the debt it owed its Canadian parent (who supplied the lectures), because the US LLC assumed the obligations to supply the lectures to the depositors. IRS of course says no, so we’re off to another method-madness accounting jumpball.

PPTI needs testimony and documents from the Canadian Chartered Professional Accountants, who served as advisors and accountants in setting up the deal.

So Judge Gustafson goes to his form file, and checks out the Canada Evidence Act and the British Columbia Evidence Act, and generates for document that appears at pp. 3-8.

Really playing nice.

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