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willful blindness

February 9, 2021

What Does a Willful Failure to Report Offshore Accounts Mean?

On this blog, we have frequently discussed the willfulness standard as it relates to one’s duty to satisfy offshore financial accounts and offshore income generating asset […]
February 6, 2017

A Deliberate or Willful Blindness Jury Instruction Is Rarely a Good Sign for a Criminal Tax Defendant

Recently on the Federal Tax Crimes blog, the tax fraud case of Happy Asker was analyzed in the context of the willful blindness jury instruction given […]