The Fifth Amendment’s Essential Role in Offshore Audits 2.5 Credits
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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.
Major topics covered in this course:
Join this CE Tax Course to understand how the Fifth Amendment's privilege against self-incrimination can be a game-changer in such cases.
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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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We issue instant credit certificates, ensuring they are valid for presentation to governing bodies. Typically, we report IRS, CTEC, CFP, IDFP, IWI, VBOA Ethics credits within 7 days – the fastest in the industry.
DC
the instructor was great. Very interesting course topic
BG
Great topics and convenient schedules!
Dec 23, 09:00 AM ET
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Dec 23, 11:00 AM ET
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