Not So Fast, IRS…My Client Wasn’t Aware: Marinello v. United States
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Mar 26, 2018 Popular Posts, Willfulness
Last Call: The Offshore Voluntary Disclosure Program to End
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Mar 17, 2018 Cross-Border Tax Insights, International Tax, OVDP, Streamlined Filing
Held Captive: Micro-Captive Insurance in the Aftermath of Avrahami
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Dec 05, 2017 Captive Insurance
The Computer Fraud and Abuse Act (CFAA)
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Oct 02, 2017 Computer Crimes, White-Collar Defense Insights
IRS Required to Return FBAR “Penalty:” Penalty was “Illegally Exacted”
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Sep 22, 2017 Bank Secrecy Act, FBAR, White-Collar Defense Insights, Willfulness
Determining the Enforceability of a Section 6038A Summons
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Sep 20, 2017 Cross-Border Tax Insights, International Tax
The Crime of Tax Evasion
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Sep 18, 2017 Criminal, Evasion, Tax Fraud, White-Collar Defense Insights
Is “Form” “Substance” When it Comes to Law? The Future of the Doctrines of Economic Substance and Substance Over Form
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Sep 15, 2017 Economic Substance, Substance over Form
