White Collar Warrior

Big Win for Taxpayers in A Watershed “Willful” FBAR Penalty Case
Listen I’m a little slow in getting around to this one, but back on September 20, 2017, the Eastern District of Pennsylvania released a taxpayer-friendly opinion regarding the “willfulness” standard in FBAR penalty cases. In Bedrosian v. United States, Case No. 2:15-cv-05853-MMB (E.D. Pa., Sept. 20, 2017), the district court held that the government had not met its burden of …
Knowing When To Say When: Tax Practitioners & The Rules Governing the Giving of Legal Advice
Listen 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 …
OVDP And Double Counting: Oh The Agony!
Listen What is this phenomenon known as double counting? Why is it important? If you are shepherding clients through the OVDP program, or you are going through the program yourself, it is critical that you understand what it means and the governing principles behind it. Otherwise, you could be paying an offshore penalty that is …
Nuts & Bolts of Storytelling For Public Speakers: How to Raise the Stakes
Listen Learning how to raise the stakes in a story is hugely important. The problem that storytellers encounter more often then any other when telling their stories is failing to show the audience that there were high stakes. When you find yourself going “Whoa…!” during a story, or when you find yourself moving to the edge of your seat anxious to …
Nuts & Bolts of Storytelling For Public Speakers: How to Tell An Unforgettable Story
Listen SIGNIFICANT DETAILS As you may have heard before, it’s better to be specific than general most of the time. Like, “the bright pink tulip in the window” is better than “a flower.” It’s said that great criminals and sociopaths are especially good at including specific details in their alibis, because specific details read as …
Harnessing The Power of Fear in Public Speaking – Tips & Tricks For An Unforgettable Presentation: Part II
Listen When you hear the words “professional speaker,” do they conjure up a particular image in your mind? What exactly does a professional speaker look and sound like? What are some of the traits that successful speakers have in common? Before we delve into this, let me take you back to 1997. That was the …
Harnessing The Power of Fear in Public Speaking – Tips & Tricks For An Unforgettable Presentation
Listen Have you ever gone to a technical talk or presentation excited about the topic, only to be frustrated by the speaker’s technical jargon and stiff delivery? If you’re a tax professional, you’ve likely been to more of these presentations than you care to remember (perhaps even reluctantly if you had perilously waited until the …
Lessons Learned From The Recent Conviction of Swiss Banking Giant Credit Suisse
Listen When European financial giant Credit Suisse AG pleaded guilty to assisting U.S. taxpayers evade federal income tax, there was a great deal of swagger at the Justice Department. Former Attorney General Eric Holder, in classic Clint Eastwood style, boldly proclaimed that “no financial institution. . .is above the law,” and that any other bank …
Today’s Criminal Justice System: Does It Live Up To What The Founding Fathers Envisioned It To Be?
Listen “A diligent prosecutor can convince a grand jury to indict a ham sandwich.” This quote by New York Court of Appeals Chief Judge Sol Wachtler was made even more famous in the Tom Wolfe novel The Bonfire of the Vanities. Apropos of nothing, Judge Wachtler also once referred to the death penalty as “the …