Tax Controversies: Audits, Investigations, Trials
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Product description
Guide to all stages of a tax examination, investigation, litigation and prosecution -- civil or criminal -- including coverage of:
• the recent repeal of TEFRA partnership entity-level audit rules; this reform will have a substantial impact on IRS audits of partnerships and partners.
• an analysis of IRC § 7345, which authorizes the Secretary of State to revoke the passport of a U.S. citizen who, as certified by the IRS Commissioner, owes a seriously delinquent tax debt.
• the latest on the quickly developing law as it relates to the search and seizure of electronic evidence from the many electronic devices used in everyday life.
• the DOJ’s new pilot program that allows a company to receive credit for reporting and remediating its own violations under the Foreign Corrupt Practices Act.
• the latest developments in the DOJ’s ongoing crusade against undeclared foreign bank accounts.
• FinCEN’s new Beneficial Ownership Rules that will apply to domestic financial institutions requiring that they identify the beneficial owners of accounts held in the name of legal entities.
• the effect of a criminal conviction on the statute of limitations for civil assessment and collection.
Volume 2 augments these discussions by providing a useful collection of valuable source material, including:
• Sample jury charges;
• Over 25 important IRS forms;
• A wide selection of Civil and Criminal litigation forms.
Table of Cases and Statutes are also provided.
eBooks, CDs, downloadable content, and software purchases are noncancelable, nonrefundable and nonreturnable. Click here for more information about LexisNexis eBooks. The eBook versions of this title may feature links to Lexis+® for further legal research options. A valid subscription to Lexis+® is required to access this content.
Table of contents
Volume 1
Chapter 1: Tax Examinations
Chapter 2: Appeals Office and Tax Court Procedure
Chapter 3: Assessments and Collection
Chapter 4: Tax Preparers and Practitioners
Chapter 5: Criminal Investigations
Chapter 6: Criminal Administrative Review
Chapter 7: Summons Power
Chapter 8: Grand Jury
Chapter 9: Search and Seizure
Chapter 10: Fifth Amendment Right Against Self-Incrimination
Chapter 11: Privileged Communications
Chapter 12: Use of the Freedom of Information Act in Tax Litigation
Chapter 13: Criminal and Civil Penalty Issues Relating to the Corporation
Chapter 14: Voluntary Disclosure
Chapter 15: Civil Penalties
Chapter 15A: Innocent Spouse Relief
Chapter 16: Criminal Charges
Chapter 17: The Bank Secrecy Act and the Foreign Account Tax Compliance Act (FATCA)
Chapter 17A: Money Laundering
Chapter 18: Asset Forfeiture
Chapter 19: Methods of Proof
Chapter 20: Defenses
Chapter 21: Sentencing
Chapter 22: Collateral Consequences of a Criminal Tax Conviction
Volume 2
Appendix I: Jury Charges
Appendix II: Civil Litigation Forms
Appendix III: Internal Revenue Service Forms
Appendix IV: Criminal Litigation Forms
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