Tag: Fifth Amendment

What’s Next in Foreign Account Enforcement?

By Sanford Millar of MillarLaw A Professional Corporation On Sunday, January 10, 2016

The Department of Justice and the IRS are now mining the wealth of data obtained through settlements  (Non-Prosecution Agreements) with almost 100 Swiss banks.  The search through the data is methodical. First the government seems to be looking for “leavers”.  Leavers are U.S. taxpayers who maintained an account at a foreign fianancial institution and who … Continue reading What’s Next in Foreign Account Enforcement?

Warning, Offshore Accounts Holders May Have No Fifth Amendment Protections

By Sanford Millar of MillarLaw A Professional Corporation On Monday, April 13, 2015

In what is becoming an increasingly used attack vehicle, the Department of Justice (DoJ) is using the “required records doctrine” to compel taxpayer’s to produce what may be incriminating evidence of ownership or control of foreign financial accounts. The DoJ process involves the issuance of a Grand Jury subpoena for records and then compelled testimony. … Continue reading Warning, Offshore Accounts Holders May Have No Fifth Amendment Protections