Jack Townsend offers this blog on Federal Tax Crimes principally for tax professionals and tax students. It is not directed to lay readers -- such as persons who are potentially subject to U.S. civil and criminal tax or related consequences. LAY READERS SHOULD READ THE PAGE IN THE RIGHT HAND COLUMN TITLE "INTENDED AUDIENCE FOR BLOG; CAUTIONARY NOTE TO LAY READERS." Thank you.
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Monday, December 21, 2009
Requirement to Notify Attorney General of Foreign Proceedings
This item is a bit late in the cycle of tax crime news, but I thought I would post it anyway as a resource for readers since the issue may arise in later cycles of offshore account advice and maneuverings. Readers will recall that 18 U.S.C. § 3506 requires that U.S. persons contesting in a foreign country a U.S. request to that foreign country for information must notify the Attorney General of the foreign proceeding. Readers desiring further information on this issue will find a good resource on the web in the form of a Pillsbury Winthrop Shaw Pitmann LLP memorandum from Stephan E. Becker to Michael Leupold and Suzanne Kuster dated 9/6/09. The memorandum is here.
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