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Fifth Amendment Bank Secrecy Act

When the Fifth Amendment Privilege Doesn't Work-Tax Cases

by Sanford Millar on

A recent decision of the Third Circuit Court of Appeals illustrates the futility of expecting that the Fifth Amendment Privilege Against Self-incrimination will shield taxpayers from production of offshore financial records. ...more

No Records is Not an Acceptable Excuse

by Sanford Millar on

Often taxpayers who have not filed Reports of Foreign Bank or Financial Accounts (FBAR’s) will claim that they do not have records of their offshore accounts, because the accounts are maintained by third parties. In many...more

Eleventh Circuit Holds that Production of Foreign Bank Account Records May be Compelled in Criminal Investigation Under Required...

by Saul Ewing LLP on

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

Must You Produce Records of Offshore Accounts?

by Sanford Millar on

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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Cybersecurity

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