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How the Rise in Undercover Investigations is Changing the Law  [Video]

Jan. 19, 2015 (Mimesis Law) -- Robert Blecker, professor of law at New York Law, talks with Lee Pacchia about the dramatic rise in undercover investigations and their effect on the legal defense of entrapment....more

North Carolina ABC Legislative Wrap-Up 2014

The 2014 legislative short session adjourned on August 20, 2014. The General Assembly passed several bills affecting alcoholic beverages in North Carolina. Significant provisions of those bills are summarized below....more

Part VI – Willful Or Non-Willful Offshore Omissions & Conclusion

Below is Part 6 and the conclusion of my partner, Rick Josepher’s, analysis of the new offshore enforcement environment in light of the new 2014 Offshore Voluntary Disclosure Procedures....more

Focus on Tax Controversy and Litigation - July 2014

In this issue: - Supreme Court Limits Taxpayer’s Ability to Examine the IRS at a Summons Enforcement Hearing - Court Determines Tax Analysis not Protected by Attorney-Client Privilege and Work Product Doctrine...more

Can an OVDP Participant Set Aside a Closing Agreement on the Theory of Duress?

It has been just over five years since the Internal Revenue Service (“IRS”) offered the first of three offshore voluntary disclosure programs for individuals with undisclosed foreign financial accounts. Since the announcement...more

Court’s Ruling Holding Corporate Officer Responsible for Trust Fund Recovery Penalty Illustrates Risk of Personal Liability for...

A district court in the Northern District of California has held that the officer of a now-defunct corporation is personally responsible for the Trust Fund Recovery Penalty based upon the company’s failure to collect, account...more

McIntyre: Not What You Bargained For?

When are the parties to a civil tax dispute bound by agreed facts from a criminal proceeding? This was the question considered by the Tax Court of Canada on a Rule 58 motion made by the taxpayers in McIntrye et al v....more

District Court Rules for Taxpayer in STARS Case Santander Holdings; Court of Federal Claims Rules for Government in STARS Case...

In this issue: - Swiss Bank Settlement Dilemma - District Court Upholds STARS Transaction Ruling Payment Is Included in Pre-Tax Profit - Court of Federal Claims Holds for Government in BB&T STARS...more

Congressional Investigations: Unique And Significant Risks

We have all watched the familiar scene on Capitol Hill – the latest public scandal like officials from the Internal Revenue Service are dragged up to Capitol Hill to appear before a Committee, raise their right hands, take...more

Search Warrants - Is it a rubber stamping process ?

A - and- Her Majesty's Revenue & Customs ("HMRC") : Challenge, the lawfulness of a search warrant issued by HMRC in the HIGH COURT OF JUSTICE - Some clarification on this point has been provided in a recent case in which...more

From the intrusive to the abusive – what happens when the CRA goes too far?

In order to administer and enforce the self-reporting system of tax assessment in Canada, the Income Tax Act (ITA) and Excise Tax Act (ETA) provide the CRA with the power to demand certain information from taxpayers....more

Is the Tax Adviser Privilege a Trap for the Unwary?

As we approach April 15th many taxpayers will meet with professional tax advisers and some may be under the impression that communications between a taxpayer and a tax adviser are privileged. This assumption is wrong as...more

Professional Ethics In A Tax World – Self-Assessment, Self-Incrimination, The Charter, Crown Fairness And Other Matters

TABLE OF CONTENTS 1.0 INTRODUCTION .... 1 2.0 KEY PRINCIPLES .... 3 2.1 “Voluntary” Self-Assessment .... 3 2.2 The Nature of Tax Penalties .... 4 2.3 Right Against Self-Incrimination .... 5 2.4...more

Mofo New York Tax Insights - March 2011 - Volume 2, Issue 3

In this issue: Taxpayer’s Testimony Fails to Establish Non-Residency; New Unit in A.G.’s Office to Pursue Tax Claims Under False Claims Act; ALJ Vacates Demand for Bill of Particulars; Non-Profit’s 99-Year Lease Insufficient...more

FBAR Penalty Relief

In U.S. v. Williams decided 9/01/2010, the U.S. District Court in the Eastern Dist of Virginia entered a decision in favor of the taxpayer rejecting the governments assertion of willfulness and finding in favor of the...more

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