The IRS and the Justice Department have increased their efforts regarding criminal investigation of international tax evasion. ...more
Introduction - On April 30, 2013, the United States Department of Justice issued a “John Doe Internal Revenue Code” summons to Wells Fargo Bank, as a provider of correspondent bank services for Canadian Imperial Bank...more
The Eleventh Circuit recently joined the Fifth, Seventh, and Ninth Circuits in holding that subpoenaed foreign financial records properly fall within the Required Records Exception to the Fifth Amendment privilege against...more
On February 7, 2013, the U.S. Court of Appeals for the Eleventh Circuit affirmed the decision of the U.S. District Court for the Northern District of Georgia holding that the Required Records Exception overrides a...more
Recently, two Israeli banks are reported to have agreed to cooperate in criminal tax investigations being conducted by the Criminal Tax Division of the U.S. Department of Justice. The specific actions allegedly involve a...more
Some taxpayer’s who think that they have properly relied on the advice of professionals and should therefore be able to avoid FBAR penalties need to consider what constitutes “reasonable cause”. First, the reasonable cause...more
EB-5 Visas are sought after investment based pathways to a Green card. An EB-5 Visa is described in Wikipedia as follows...more
A Petition to the U.S.Supreme Court may result in the Court deciding whether a taxpayer who has a previously unreported foreign financial account must produce records of the account in a criminal proceeding in spite of the...more
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