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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

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

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