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Friday, February 27, 2009

The Mega Trial and Jurors' Attention Span

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Although not a tax crimes case and, indeed, not a criminal case at all, a recent SEC civil case is interesting for the criminal tax lawyer i...
Wednesday, February 25, 2009

Tax Shelter Penalties -- Other Costs of Being a Player

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Practitioners tend to focus principally on civil and criminal tax penalties when trying to discourage clients (taxpayers or promoters) from ...

UBS U.S. Clients Sue in Switzerland -- Dumb or Smart?

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The New York Times reported today that some "wealthy" U.S. taxpayers are suing UBS and Switzerland's Financial regulators to ...
1 comment:
Monday, February 23, 2009

The Confrontation Clause and Tax Shelter Promoters Tax Evasion

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In trials of tax shelter promoters, the Government may charge tax evasion with respect to unindicted taxpayers who bought into the allegedly...
Saturday, February 21, 2009

The UBS Mess / Opportunity (2/23/09)

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After some build up, this week the Government went public with its heavy hammer to UBS -- I resist the temptation to say private parts, but ...
Thursday, February 19, 2009

Tax Crimes Student Review and Exercise (2/29/09)

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I write this news item particularly for the students in the course in Tax Fraud and Money Laundering that Larry Campagna and I teach at the ...
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Friday, February 13, 2009

Continuing Offense Doctrine - the Last Act of Evasion

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A decision by the Eight Circuit reminds us of the importance of focusing on the last act in furtherance of a tax crime is committed. In San...
Thursday, February 12, 2009

Proposed Expansion of Money Laundering to Cover Tax Crimes

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UPDATE AS OF MAY 26 2009: The House version of this bill did not include the expansion of money laundering for tax crimes and the House pre...
Tuesday, February 10, 2009

Thoughts on KPMG Criminal Tax Trial

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"The Biggest Tax Fraud Case in History." That's how the Government touted its case involving tax shelters promoted by KPMG. ...
1 comment:

DOJ Tax Appellate Brief in Snipes Case

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The Government has filed its appellate brief in the Snipes case. You will remember that Wesley Snipes was acquitted of a Klein conspiracy (...

Is the Civil Audit a Set Up?

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The Internal Revenue Manual directs revenue agents conducting a civil examination to refer the case to the Criminal Investigation branch (...
3 comments: