The Wyly brothers made an immense fortune for themselves, employees and stockholders through investments in Michaels Stores and several software companies. They had been accused of avoiding their tax obligations by transferring stock options in Michaels and Sterling Software Inc. to offshore trusts after receiving advice from a lawyer who promoted foreign trusts as a method of asset protection and tax deferral. On May 12, 2014, a civil jury in New York found the Wyly brothers liable on counts for use of offshore trusts. On July 11, 2014, Sam Wyly and his late brother Charles, were found not liable for insider trading by a U.S. Judge in New York.
On October 19, 2014 Sam Wyly filed for Chapter 11 bankruptcy, having lost one of the cases brought by the SEC, and wanting to force the IRS to “put up or shut up” about any taxes he owed related to his family's offshore trusts. The IRS had been auditing his tax returns for a decade without ever telling him whether he owed any additional taxes.