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Should College Athletics Go Corporate?

Millions of Americans spent much of their holiday weekend watching college football. While fans around the country enjoyed watching Auburn’s thrilling win in the Iron Bowl or seeing Ohio State hold on against its arch-rival...more

12/4/2013 - Athletes Colleges Johnny Football NCAA NCLC Sports Students Universities

The DOJ Ratchets Up Its Crackdown On Swiss Bank Accounts

In my last post, I discussed the possibility that Bitcoins and other virtual currencies could replace Swiss bank accounts as the tax havens of the future. Recent developments in the government’s war on offshore accounts...more

9/25/2013 - DOJ Foreign Banks IRS Offshore Banks Offshore Funds OVDP Tax Evasion

Goodbye Switzerland. Hello Bitcoins.

Bitcoins are everywhere. Last week, a federal judge in Texas held that the virtual currency qualifies as a form of money and allowed the SEC to charge a promoter of a scheme to invest in bitcoins with violations of the...more

8/14/2013 - Bitcoins FinCEN Fraud SEC Securities Virtual Currency

Bank Leumi Snafu Jeopardizes DOJ-IRS Offshore Enforcement Initiatives

Three times over the past four years, the IRS has given taxpayers with undisclosed offshore accounts the opportunity to come clean and avoid prosecution. While the most recent offer – the 2012 Offshore Voluntary Disclosure...more

5/1/2013 - Deferred Prosecution Agreements DOJ IRS Offshore Banks Offshore Funds OVDP Pre-Clearance

Required Records, The Act Of Production And Secret Offshore Accounts

The Fifth Amendment dictates that no person "shall be compelled in any criminal case to be a witness against himself." While most non-lawyers (and many lawyers) might assume that this simple edict means the government cannot...more

2/27/2013 - Act of Production Privilege Appeals Discovery Document Productions Fifth Amendment Offshore Banks Required Records Doctrine Self-Incrimination Subpoenas Tax Evasion

The Fiscal Cliff And A Call For A Simpler Internal Revenue Code

President Obama and Speaker Boehner’s discussions aimed at avoiding the fiscal cliff will almost certainly result in the government collecting more taxes: either by increasing the rates paid by upper-income Americans, by...more

12/19/2012 - Barack Obama Fiscal Cliff IRS John Boehner

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