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
- Deferred Prosecution Agreements DOJ IRS Offshore Banks Offshore Funds OVDP Pre-Clearance
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
- Act of Production Privilege Appeals Discovery Document Productions Fifth Amendment Offshore Banks Required Records Doctrine Self-Incrimination Subpoenas Tax Evasion
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
- Barack Obama Fiscal Cliff IRS John Boehner
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