Mark E. Matthews to Speak at ABA Criminal Tax Fraud and Tax Controversy 2012 Meeting
12.06.2012
The 29th Annual National Institute on Criminal Tax Fraud is the annual gathering of the criminal tax defense bar combined with the Second Annual National Institute on Tax Controversy. This program brings together high-level government representatives, judges, corporate counsel, and private practitioners engaged in all aspects of tax controversy, tax litigation, and criminal tax defense.
Caplin & Drysdale's Mark E. Matthews will moderate a panel entitled "IRS CID Roundtable." The program, which will feature IRS Criminal Investigation Division and practitioners on the front lines discussing current and future priorities in criminal tax enforcement, will be from 11:15 AM to 12:15 PM on Thursday, December 6.
Mr. Matthews will also take part in a panel discussion entitled "Third Party Records and the Fifth Amendment: What Happened?" The program will be from 4:15 PM to 5:30 PM on Thursday, December 6.
Program Description:
The government has greatly increased efforts at obtaining information through the use of summons and subpoenas against third parties, John Doe summons, and other domestic information gathering techniques. Under the "required records doctrine," the Fifth Amendment privilege doesn't apply if: (1) the purpose of the government's inquiry is regulatory, not criminal; (2) the information requested is contained in documents of a kind the regulated party customarily keeps; and (3) the records have public aspects. Several courts have recently determined that the Fifth Amendment privilege against self-incrimination may not be used by a taxpayer under grand jury investigation defending against disclosure of undisclosed foreign account records. Leading practitioners examine the current environment and possible remaining defenses to a demand for records relating to a foreign financial account.
For further information and to register, please click here.
Caplin & Drysdale's Mark E. Matthews will moderate a panel entitled "IRS CID Roundtable." The program, which will feature IRS Criminal Investigation Division and practitioners on the front lines discussing current and future priorities in criminal tax enforcement, will be from 11:15 AM to 12:15 PM on Thursday, December 6.
Mr. Matthews will also take part in a panel discussion entitled "Third Party Records and the Fifth Amendment: What Happened?" The program will be from 4:15 PM to 5:30 PM on Thursday, December 6.
Program Description:
The government has greatly increased efforts at obtaining information through the use of summons and subpoenas against third parties, John Doe summons, and other domestic information gathering techniques. Under the "required records doctrine," the Fifth Amendment privilege doesn't apply if: (1) the purpose of the government's inquiry is regulatory, not criminal; (2) the information requested is contained in documents of a kind the regulated party customarily keeps; and (3) the records have public aspects. Several courts have recently determined that the Fifth Amendment privilege against self-incrimination may not be used by a taxpayer under grand jury investigation defending against disclosure of undisclosed foreign account records. Leading practitioners examine the current environment and possible remaining defenses to a demand for records relating to a foreign financial account.
For further information and to register, please click here.
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