A way of generating a paper loss for a high net worth individual whereby a large paper loan is made to a foreign party preceding a series of asset related swaps. The loss that is recorded by the high net worth individual will thus be equal to the loan's original value. The high net worth individual may then use the loss for the purpose of offsetting gains that they have earned.
Related information about custom adjustable rate debt structure (CARDS):
- Custom Adjustable Rate Debt Structure (CARDS) Definition ...
A type of tax shelter product used by high net worth individuals that involves making a large paper multimillion dollar loan to a foreign party. This party is usually ...
- Economic Substance and Banking Aspects of Custom Adjustable ...
The now-discredited Custom Adjustable Rate Debt Structure “CARDS” tax shelter transactions that were offered primarily to the super-wealthy (including a lot of ...
- What is custom adjustable rate debt structure (CARDS)? definition ...
Definition of custom adjustable rate debt structure (CARDS): A way of generating a paper loss for a high net worth individual whereby a large paper loan is made ...
- News - The Brattle Group
Nov 5, 2012... Internal Revenue Service that helped shape the outcome of a Custom Adjustable Rate Debt Structure (CARDS) tax dispute in U.S. Tax Court.
- News - The Brattle Group
Mar 16, 2012... Service that helped shape the outcome of a Custom Adjustable Rate Debt Structure (CARDS) tax dispute in U.S. Tax Court in Houston, TX.
- RICO — Investor's Claim Arising out of Illegal Tax Shelter Not Barred ...
Dec 28, 2010 ... It is undisputed that John Rezner participated in a financial transaction called Custom Adjustable Rate Debt Structure ("CARDS"), designed to ...
- IRANI v. UNITED STATES - Caselaw - FindLaw
May 11, 2006... with investments they made in so-called Custom Adjustable Rate Debt Structure (“CARDS”) transactions.1 The subpoena called for the Bank, ...
- RLP HOLDINGS, LP - Digital Archive @ GSU - Georgia State ...
Dec 12, 2008 ... an investment program known as Custom Adjustable Rate Debt Structure (" CARDS"). The CARDS transaction involved a loan from Defendant ...