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Curious about how the Fifth Amendment can be your secret weapon in offshore tax cases? Dive into this insightful content to unlock its hidden potential.
This course explores the crucial role of the Fifth Amendment in the context of offshore tax audits. It begins by highlighting the inherent tension between the government and taxpayers in information gathering, particularly in offshore audits where the government often relies on incomplete or inaccurate foreign bank data. The course stresses that taxpayers are reluctant to assist the IRS due to the potential criminal implications of the information they may provide.
It delves into the Fifth Amendment's privilege against self-incrimination, emphasizing that this privilege extends beyond live testimony to include the act of producing courses. Key legal cases, such as Fisher and Hubbell, are discussed to illustrate the complexities of applying this privilege in course production cases. Notably, the course explores the implications of the "required records exception" and recent legal developments that have narrowed its scope in cases involving alleged Bank Secrecy Act violations.
The course concludes by advising tax practitioners to be vigilant in asserting all available privileges to protect their clients' rights, particularly in offshore audit scenarios. It stresses the importance of understanding the evolving legal landscape and how recent court decisions, like Greenfield, have impacted the use of the Fifth Amendment privilege in response to IRS requests for foreign bank account records.
Join this CE Tax Course to understand how the Fifth Amendment's privilege against self-incrimination can be a game-changer in such cases.
Major topics covered in this course:
Partner, DeBlis Law
Michael is a trial lawyer. He graduated Cum Laude from The Thomas M. Cooley Law School and Summa Cum Laude from the Thomas Jefferson School of Law with his Masters of Law in Taxation. Michael is known for his charismatic personality and his unyielding dedication to his clients.
Michael spent the first five years of his legal career as a public defender in the NJ Office of the Public Defender cutting his teeth on some of the most serious felony cases to pass through the state courts of New Jersey. He then joined his father's law practice, DeBlis Law, expanding the practice into civil tax controversies and international tax compliance.
As a graduate of the National Criminal Defense College, Michael has trained under some of the best-known criminal defense attorneys in the country. That experience has taught him that justice for a person accused of a crime is only won through a full understanding of the client and the case.
To that end, Michael attempts to understand each client’s case as a convincing narrative, not just as a set of innocuous facts and arcane legal rules.
When he's not in the courtroom, you can find Michael on stage. He is a professionally-trained actor who has performed in off-Broadway productions and on-stage at Shakespeare in the Park. Michael's passionate about helping trial lawyers harness the power of persuasion and positive communication in the courtroom in order to connect to the jury on a human level.
Michael's training as an actor allows him to combine a unique blend of left-brain thinking with right brain artistry to make even the most dull and abstract areas of the law come to life.
Michael is a prolific writer and a passionate blogger. He has written articles that have been featured in leading tax journals and "Law 360."
Michael is a living example of the tremendous power that comes from combining passion, preparation, persuasion, and positive communication in the courtroom. His courage and relentless work ethic have earned him a reputation as a zealous advocate and one of New Jersey’s rising stars of the legal profession.
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MY-CPE LLC, 1600 Highway 6 south, suite 250, sugar land, TX, 77478
MY-CPE LLC (Sponsor Id#: GEHNZ) has entered into an agreement with the Internal Revenue Service, to meet the requirements of 31 Code of Federal Regulations, section 10.6(g), covering maintenance of attendance records, retention of program outlines, qualifications of instructors, and length of class hours. This agreement does not constitute an endorsement by the IRS as to the quality of the program or its contribution to the professional competence of the enrolled individual. Credit earned by attendees with a PTIN will be reported directly to the IRS as required of all providers. To ensure your CPE hours are reported, update your profile in My Account to include your PTIN number. Please note: IRS CE is only mandatory for EAs and ERPAs. For all other tax return preparers, CE is voluntary.
MY-CPE LLC, 1600 Highway 6 south, suite 250, sugar land, TX, 77478
MY-CPE LLC (Sponsor Id#: 143597) is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: www.NASBARegistry.org.
MY-CPE LLC, 1600 Highway 6 south, suite 250, sugar land, TX, 77478
MY-CPE LLC (Sponsor ID# : 6273) has been approved by the California Tax Education Council to offer continuing education courses that count as credit towards the annual “continuing education” requirement imposed by the State of California for CTEC Registered Tax Preparers. A listing of additional requirements to register as a tax preparer may be obtained by contacting CTEC at P.O. Box 2890, Sacramento, CA, 95812-2890, toll-free by phone at (877) 850-2832, or on the Internet at www.ctec.org.
9 Ratings
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DC
Dec 31st, 2023
the instructor was great. Very interesting course topic
JSM
Dec 29th, 2023
Really good presentation.
LB
Jan 8th, 2024
Excellent Webinar
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