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Fifth Amendment › Summons › Internal Revenue Service

Cadwalader, Wickersham & Taft LLP

IRS’s Crypto John Doe Summons Expanded While Harper Fights Back

Cadwalader, Wickersham & Taft LLP on

Since at least 2016 the IRS has been ferreting out taxpayers who failed to report their taxable gains from cryptocurrency transactions by issuing John Doe summonses to crypto exchanges and dealers. A John Doe summons enables...more

A&O Shearman

Focus on Tax Controversy and Litigation - The Unprecedented Extraterritorialization of Tax Crimes

A&O Shearman on

In addition to the discussion of the recently proposed U.K. criminal tax legislation, this month’s issue features articles regarding the Tenth Circuit Court decision in McNeill v. United States discussing a managing partner’s...more

Akerman LLP

Supreme Court to Decide When Taxpayers Can Obtain an Evidentiary Hearing in a Summons Enforcement Action

Akerman LLP on

On January 10, 2014, the Supreme Court granted review of an Eleventh Circuit case addressing the circumstances under which a taxpayer can obtain an evidentiary hearing in challenging a summons issued by the Internal Revenue...more

BakerHostetler

Ninth Circuit Holds that Fifth Amendment Does Not Shield Taxpayer's Attorney from Forced Production of Client-Taxpayer's Records

BakerHostetler on

Applying the “foregone conclusion” exception to the Fifth Amendment privilege against self-incrimination, the Ninth Circuit held on January 8, 2013, that the IRS could force a taxpayer’s criminal defense attorney to turn over...more

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