This article recently appeared in the November/December 2014 Edition of CCH’s Journal of Tax Practice & Procedure: Making Sense of the Model 2 FATCA Agreement
Six years into the government’s latest crackdown on offshore tax evasion, federal prosecutors have yet to win a signature jury trial. Of the 38 persons
When we last left our anthropomorphic friends, Rigby was in a serious coma due to an allergic reaction from the eggs in the Eggscelent omelet,
Juries wants to do the right thing. They need someone to follow. Who will they follow? According to Gerry Spence, “juries will follow the one they
I recently wrote a two-part series about the inadequate justification for the United States’ worldwide taxation of its nonresident citizens (Part I is available here;
In a recent blog entitled, “FATCA GIIN January 2015 FFI Registration Analysis … by the numbers,” Professor William Byrnes provides a brilliant commentary on the
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