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Tax Evasion

March 25, 2014

I concealed bank accounts from the government

Case law has held that one commits attempted tax evasion (a felony) under IRC Section 7201 when (1) he fails to file a tax return and […]
March 25, 2014

International tax investigations are an IRS high priority

International tax investigations are an IRS high priority International tax compliance is currently a top priority of the IRS. The IRS perceives a pattern of abuse […]
March 21, 2014

CPA aiding and abetting in criminal tax fraud

Several crimes set forth in the Federal Criminal Code can apply to CPAs in their capacity as tax preparers, advisors and representatives of clients. The most […]
June 18, 2013

Why enter into a proffer agreement?

A proffer agreement is embodied in written form by a proffer letter. The agreement allows those who may be subject to criminal investigation, either as a […]
June 18, 2013

Why to have an attorney to review a proffer agreement

The very short answer is “Because the devil is in the details”—and because what you state in a proffer session with the government can be used […]
June 18, 2013

What is a proffer agreement and what are the risks?

A proffer agreement is sometimes made in criminal tax cases. It is an agreement, usually written, between a federal prosecutor and an individual who are under […]