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Posts Tagged U.S. tax attorney

DOJ Tax Division’s 97% Conviction Rate

Around our office we call the Justice Department Tax Division’s conviction rate the “body temperature” index. If the body’s temperature falls much below 98 degrees, something is very wrong. Ditto if a DOJ criminal tax lawyer can’t obtain a conviction in 97% of cases. This post examines the story behind the story. U.S. District Court [...]

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Feds Proposed New Felony Tax Crime Has Implications For Those Overseas

by Brian Mahany Tax evasion is a felony. Prosecutors must prove that the person accused possessed a willful intent to evade taxes and committed some affirmative or overt act of evasion. Mere failure to pay taxes or file returns are misdemeanors punishable by no more than a year in prison. The difference is the required [...]

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Congressman Rips FATCA

by Brian Mahany The Foreign Account Tax Compliance Act (FATCA) doesn’t have many friends these days. Tens of thousands of taxpayers – mostly foreign born Americans, dual nationals, green card holders and Americans living abroad – were caught completely unaware of the foreign reporting requirements. Despite a PR campaign by the IRS, many still are [...]

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