The Fifth Amendment privilege against self-incrimination does not apply to records that fall under the Required Records Doctrine, and a taxpayer who is the subject of a grand jury investigation into his use of offshore bank accounts cannot invoke the privilege to resist compliance with a subpoena seeking records kept pursuant to the Bank Secrecy…
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About: Ronald Marini
Recent Posts by Ronald Marini
IRS Rules – May adopt a CAP Decision as part of a CDP Hearing
The IRS Office of Chief Counsel said in a program manager technical advice memorandumPMTA2012-14, that a settlement officer may adopt the CAP decision as part of the determination in the CDP hearing but is not required to do so. 1) Section 6330(c)(4) does not preclude consideration during a CDP hearing of an issue that…
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Doctor Convicted for Hidding $8 Million in Secret Offshore Accounts in India & HSBC
Acccording to the DOJ - A jury convicted Arvind Ahuja yesterday on federal tax charges stemming from his failure to disclose offshore bank accounts maintained in India and the Bailiwick of Jersey, the Justice Department and Internal Revenue Service (IRS) announced. Trial began on Aug. 15, 2012 before U.S. District Judge Charles N. Clevert, Jr.,…
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Tax Evasion Potential of Foreign Parent Groups primarily operating in U.S. Analyzed by GAO
A new report by the Government Accountability Office (GAO) has analyzed the prevalence of, and potential tax advantages or abuse stemming from, foreign-parented corporate groups with U.S. subsidiaries that conduct the majority of their worldwide operations in the U.S. Although information on the subject was limited, GAO concluded that this structure may provide an advantage…
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