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Wednesday, March 31, 2010

The Swiss / UBS Fix is in (Almost)

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This is perhaps ho-hum by now, but the Swiss today announced here that Switzerland has taken a major step in fixing Swiss law to ex post fa...

Tax Shelter Lawyer Gets Probation

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Peter Cinquegrani, a former Arnold & Porter partner, dodged the jail time bullet and was sentenced to only three years probation. He had...
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More on Honest Services Fraud

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I picked up today from Ellen Podgor's White Collar Crime Prof Blog the Vanderbilt Law Review En Banc Roundtable papers on Skilling v. U...
Friday, March 26, 2010

The Value of Broadly Worded Protective Orders

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In SEC v. Merrill Scott & Associates , ___ F.3d ___ (10th Cir. 2010) , the taxpayer, an alleged tax evader, "invested money with de...
Tuesday, March 23, 2010

Altria #3 - What Were Those Guys Smoking? (3/23/10)

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Today is my final installment on Judge Holwell's Altria decision. I today have nothing to offer of tax substance (without making any cl...
Monday, March 22, 2010

Altria #2 - Economic Substance and Juries (3/22/10)

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In Altria (see blog here for introduction), Judge Holwell submitted the issues to the jury as follows: The Court instructed the jury to...

Economic Substance Jury Instruction in Larson/Pfaff/Ruble (3/22/10)

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I previously attached deep in a blog Judge Kaplan ’s economic substance charge to the jury in United States v. Larson (S.D. N.Y. No. 05 CR ...
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Saturday, March 20, 2010

Altria # 1 - Frank Lyon and tax shelters (3/20/10)

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I write today about a decision in a refund suit because it involves a jury verdict in a highly structured tax shelter. I have spent some wor...
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The Reliance Defense as Bearing on Willfulness: Expert Testimony (3/20/10)

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The issue in a tax crimes case having a willfulness element (all of the significant ones except the tax obstruction crimes) is whether the d...
Wednesday, March 17, 2010

Restitution in the Coplan Tax Shelter Enabler Case (3/17/10)

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In United States v. Coplan (SD NY No. (S1) 07 Cr. 453 (SHS), the Government wanted to prove the restitution amount through the closing agre...

Klein Conspiracy Instruction (3/17/10)

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In United States v. Coplan (SD NY No. (S1) 07 Cr. 453 (SHS), Judge Stein gave the following jury instruction on the Klein / defraud conspi...

More on the Honest Services Supreme Court Cases and Tax Obstruction

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I have previously blogged here the possibility that the pending cases before the Supreme Court on honest services fraud might portend some ...

More on Economic Substance in Criminal Tax Cases - the Coplan Instructions.(3/17/10)

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I have previously blogged on the application of the economic substance doctrine in criminal cases. I offer in this blog the application of t...
Tuesday, March 16, 2010

Foreign Account Tax Compliance Act of 2009 (FATCA) Near Passage

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Tax Notes Today reports this morning that the Senate is poised to pass the Foreign Account Tax Compliance Act of 2009 (FATCA) as part of the...
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Another Foreign Bank in the U.S. Government Sights

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A series of news articles appear this morning centered around a statement made by the IRS Special Agent in Charge of the Tampa Field Office....
Saturday, March 13, 2010

Obstruction of Justice At Trial

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In United States v. Dehlinger , 2010 U.S. App. LEXIS (4th Cir. No. 09-4099 2010) (unpublished opinion, here ), the Fourth Circuit gives a ca...

Downing Warns Taxpayers and Tax Practitioners

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Tax Notes Today for 3/8/10, in an article titled Jermiah Coder, Practitioners Handling Offshore Account Cases Warned About Sanctions for Non...
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More on the Yip Criminal Case - FBARs and other Matters (3/13/10)

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I have previously blogged here on the Ninth Circuit's published decision in United States v. Yip , ___ F.3d ___ (9th Cir. 2010) . That ...