This program, presented by seasoned crimInal and tax law attorney Michael DeBlis III, will explore how the Fifth Amendment applies to offshore tax audits.
The Fifth Amendment is normally associated with criminal proceedings and the prohibition against self-incriminating testimony. However, the Fifth Amendment is a little broader than that. Its protections also apply in some pseudo-criminal matters, such as contempt of Congress. More importantly, for tax law purposes, there is a documentary production privilege. There is a trio of cases that flesh out this concept. This program will examine those three cases and more. In this comprehensive overview, DeBlis will review the Fifth Amendment’s application to tax law cases, including a discussion of the Fifth Amendment’s privileges and defenses, Act of Production immunity, the Bank Secrecy Act, and how to invoke the Fifth Amendment to object to IRS summonses.
Superb presentation with excellent reference materials.
Great content on this one. thank you.
Excellent presentation concerning criminal law testimonial privilege in tax law context.
Very interesting indeed.