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Tuesday, July 27, 2010

What is the Foregone Conclusion To Overcome the Fifth Amendment Act of Production Doctrine? (7/27/10)

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The IRS summons is a substantial tool in the investigation of tax liabilities and of crimes related to taxes. The summons is compulsory proc...
18 comments:
Saturday, July 24, 2010

The Limits of Literal Truth as Defense to Perjury (or Even 18 USC 1001) (7/24/10)

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Bronston v. United States , 409 U.S. 352 (1973), here , is frequently cited for the proposition that literal truth is a defense to a charge ...
9 comments:

Certificate of Innocence and Damages for Wrongful Incarceration (7/24/10)

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A wrongfully convicted defendant may sue for damages arising from the incarceration under certain very narrow conditions specified in 28 U.S...

Update on Swiss Turnover of Documents Pursuant to Treaty Request (7/24/10)

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I reported earlier today that the Swiss Administrative Court has approved the treaty request, thus opening the door to turnover of the 4,450...

Swiss Court Rejects Last Hopes of U.S. Depositors (7/24/10)

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In perhaps an anticlimax, on July 19, the Swiss Administrative Court formally torpedoed the hopes of anonymous U.S. depositors within the gr...
Wednesday, July 21, 2010

Sentencing Judge Off the Sentencing Reservation

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I am somewhat behind on this item out of the Second Circuit, United States v. Woltmann , 610 F.3d 37 (2d Cir. 2010) , decided July 6. The ca...
Tuesday, July 20, 2010

Even More on DOJ Authority to Investigate Tax Crimes (7/20/10)

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I have previously blogged this issue here to address DOJ Tax's claims that it has authority to investigate tax crimes. I had cited the ...
4 comments:
Saturday, July 17, 2010

Wesley Snipes Conviction and Sentence Affirmed (7/17/10)

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As the world (including likely readers of this blog) know, Wesley Snipes was convicted of 3 counts (years) of failure to file (while being ...
1 comment:
Friday, July 16, 2010

Germany Continues Aggressive Moves Toward the Swiss Tax Cheat Enablers

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German authorities are raiding German offices of Credit Suisse. As noted in one article (Reuters from 7/16/10): Raids at Credit Suisse (CS...

Swiss Lawyer Indicted for Offshore Account Activity

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DOJ Tax has this press release, dated 7/15/10, announcing the indictment of a Swiss enabler: Swiss Lawyer Indicted for Helping to Hide Swiss...
Wednesday, July 14, 2010

Rumors that Downing May Leave DOJ Tax for More Gainful Employment

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Kevin Downing who made such headlines in the KPMG tax shelter criminal case and in the offshore account initiative may be leaving DOJ Tax fo...
2 comments:
Friday, July 9, 2010

Willfulness - Non Tax Contexts

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I have written on the willfulness element for most federal tax crimes previously. Yesterday, I read on the White Collar Crime Prof blog here...

Leak From HSBC Suggests U.S. Taxpayers Continuing to Hide Offshore Assets Should Re-Think Their Model

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The Wall Street Journal has an interesting article this morning on the leak of information from HSBC to at least some tax authorities. The a...
1 comment:
Thursday, July 8, 2010

More on HSBC Initiative and DOJ Tax Division Authority to Conduct Criminal Tax Investigations

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The Wall Street Journal has an article today here with further discussion of the new HSBC initiative which I discussed earlier here . I jus...
6 comments:

Excessive Fines -- Forfeiture and FBAR Penalties (7/8/10)

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On July 7, the Second Circuit rendered a significant forfeiture decision ( United States v. Castello , 611 F.3d 116 (2d Cir. 2010) ), that b...
7 comments:
Wednesday, July 7, 2010

Government Sends Message to Aged and Infirm Offshore Bank Account Owners

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The Government squeezed a plea from one Leonid Zaltsberg, a UBS depositor. On some factors, he looked liked a prime target. He had a high ba...
Tuesday, July 6, 2010

Lawyer Pleads Guilty to Two Misdemeanor Counts of Failure to Pay

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Various sources report that so-called celebrity lawyer, Mickey Sherman , has pled to two misdemeanor counts of failing to pay $400,000 in ta...
3 comments:
Sunday, July 4, 2010

Another Instance of Government Misconduct in a Tax Case

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In United States v. Struckman, ___ F.3d ___ (9th Cir. 2010) , the Ninth Circuit, as did the District Court, found that the Government commit...
1 comment: