Tax Controversies: Audits, Investigations, Trials
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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.
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Table of contents
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
Appendix I: Jury Charges
Appendix II: Civil Litigation Forms
Appendix III: Internal Revenue Service Forms
Appendix IV: Criminal Litigation Forms