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Required Records Doctrine

When Offshore Asset Protection Fails

by Sanford Millar on

What happens when The IRS attacks your offshore asset protection plan? The simple answer is you may face a variety of civil and criminal investigations and penalties. What constitutes an offshore asset protection plan?...more

IRS and DOJ Use a New Method to Defeat Taxpayers’ Fifth Amendment Argument Against Turning Over Foreign Account Records

by BakerHostetler on

At virtually every turn, courts have ruled against taxpayers who have asserted their Fifth Amendment privilege against self-incrimination to avoid turning over foreign account records to the government, citing the “Required...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

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

by Sanford Millar on

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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