Required Records Doctrine

News & Analysis as of

No Records is Not an Acceptable Excuse

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

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

Offshore Banks, Required Records and Secret Funds Transfers: a Receipe for Disaster

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

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