Dr. Bulb’s financial advisor, Clem Cudchewer, told him about setting up an Asset Protection Trust with some bank, he’d never heard of in Alaska. He received a really nice brochure from the Bank touting its services and his advisor told him that since he wouldn’t control the money (except to direct how it was invested), it was safe from creditors. He called his lawyer, Luigi Linguini. Luigi was concerned about whether a Domestic Trust would provide him all the protection he needed. So, he advised Dim to also set up a Foreign Asset Protection Trust with a bank in Nevis (a place Dim had never heard of before). Luigi and Clem arranged for Dim to sign the paperwork and forward the money to Nevis and Alaska. There were some vague promises about saving taxes as well, but Dim didn’t understand any of this since, he was focused on being a good Doctor and left these other issues up to professionals. He let his malpractice coverage lapse.

After the funds were received in Nevis, Congress passed the Foreign Compliance Tax Account Act of 2009 which required Banks which had any nexus with the United States to report income and expenses on the accounts of any US taxpayers.