The Fifth Amendment’s Essential Role in Offshore Audits – Part II [Podcast]
The Fifth Amendment’s Essential Role in Offshore Audits – Part I [Podcast]
IRS Summons Power [Podcast]
How the IRS Reconstructs Income In Tax Fraud Cases
In one of the climactic scenes from 1954’s On The Waterfront, Crime Commission prosecutors had to make their corruption case against union boss Johnny Friendly (a/k/a Michael Skelly) by convincing a reticent yet pure-hearted Terry Malloy to come forward and tell what he knew about corruption in the International Longshoremen’s Association, beginning with the murder […]
Essential Elements of Tax Crimes
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Tax Crimes That The Government Relies Upon in offshore bank tax prosecutions
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Walking The Sawdust Trail
Those who responded to the altar call after one of Billy Sunday’s sermons were said to walk the sawdust trail, because the temporary venues he preached in back in the 1910s and 1920s often had sawdust on the floor as a deodorizer. Before he became a travelling evangelist, and possibly even before he became a […]
Knowing When To Say When: Tax Practitioners & The Rules Governing the Giving of Legal Advice
During its previous term, in a case that definitely took a back seat to the Affordable Care Act, same-sex-marriage, and the other high-profile disputes that the Supremes attempted to resolve, the High Court might have changed the way that doctors, dentists, accountants, lawyers, and other professionals have done business for decades. In North Carolina State […]
Overcoming The Pitfalls of Certifying Non-Willfulness When Applying To The Streamlined Compliance Program
Of the recent changes made to the streamlined procedures, none have received as much attention – or stirred up as much debate – as the new rule requiring certification of non-willfulness as a condition for gaining entry. This blog focuses on the requirement of the new streamlined procedures that the failure to report income from […]
How ‘Big Brother’ Gathers Information in the Digital Age: A Free Webinar
Click on the banner below to get access to the free webinar: How ‘Big Brother’ Gathers Information in the Digital Age.