ABA 27th Annual National Institute on Criminal Tax Fraud to Convene in San Francisco

WASHINGTON, D.C., Nov. 29, 2010 — The Hotel Nikko in San Francisco will be the site of the 27th Annual National Institute on Criminal Tax Fraud, sponsored by the _ Criminal Justice Section, Section of Taxation and Center for Continuing Legal Education.  Sessions during the meeting, which occurs Dec. 2-3, will look at updates and developments in tax fraud.

Specifically, panel discussions will focus on enhancement of the government’s enforcement efforts targeting offshore accounts, the use of foreign evidence at trial, “Top Five” practice tips for the criminal tax practitioner, the continuing controversy regarding the application of the federal sentencing guidelines, and an overview of nuts and bolts techniques for responding to a criminal tax fraud investigation.

Panelists representing private practice and government will speak on the following topics:

“Department of Justice Criminal Tax Roundtable” will feature prosecutor representatives from the Department of Justice Tax Division and the U.S. Attorney’s office (Southern District of Florida).
Dec. 2, 9 a.m.

“IRS Criminal Tax Roundtable”
Dec. 2, 9:50 a.m.

“Money Laundering, Forfeiture and Restitution: Show Us the Money” — Panelists will explore anti-money laundering enforcement and its connection to tax enforcement, including current developments regarding anti-money laundering activities, forfeitures, structuring transactions and currency reporting.
Dec. 2, 10:50 a.m.

“Obtaining and Use of Foreign Evidence at Trial” — A panel of prosecutors will focus on offshore tax matters including international mutual legal assistance treaties, the Foreign Account Tax Compliance Act, John Doe summons and more.
Dec. 2, 11:15 a.m.

“Civil Penalty Considerations: During and After the Criminal Investigation” — Panelists will explore issues of reliance, reasonable cause and good faith for the guilty tax defendant.
Dec. 2, 1:30 p.m.

“Sensitive Issue Examinations up to the Criminal Referral” — Panelists will discuss the question “Have IRS fraud technical advisors removed the legs from Tweel, the airless tire?” The focus of discussion includes parallel DOJ investigations, handling difficult civil examination practice situations, defending the indefensible position during taxpayer interviews, and taking the fifth without taking the fifth.
Dec. 2, 2:30 p.m.

“All-In: Hot Issues and Priorities in IRS Examination and Appeals” — Panelists explore current civil tax developments affecting criminal tax practitioners, including how to resolve international issues in IRS appeals, dealing with ongoing “wealth squad” examinations of high net worth taxpayers and more.
Dec. 2, 3:40 p.m.

“Ask the Experts: Top 5 Criminal Tax Practice Tips and Representation Strategies” —Panelists will offer fast-paced personal “rules of thumb” and practical guidance regarding their most difficult criminal tax practice issues.
Dec. 2, 4:40 p.m.

“Voluntary Disclosure Policies and Practice — Where Are We Now?” — This panel will explore ever-changing issues including considerations in domestic voluntary disclosures, quiet v. noisy, state voluntary disclosure policies, opting out of the offshore VDP, and the future—if any—of the IRS voluntary disclosure practice.
Dec. 3, 8:45 a.m.

“Ethical Issues: Defending Taxpayer Misrepresentations and Omissions during the Civil Examination” — This panel will answer questions such as “How should the representative respond to inquiries regarding false documents and misrepresentations?” and “Where is the line between zealous advocacy and criminal conspiracy?”
Dec, 3, 10 a.m.

“Federal Sentencing Guidelines: All I Want to do is Dance!” — This panel will discuss a practical approach to resolving the most difficult sentencing problems for the guilty client and will go beyond the math of determining the applicable guideline range.

Click here for more information about the meeting.

With nearly 400,000 members, the _ is the largest voluntary professional membership organization in the world.  As the national voice of the legal profession, the ABA works to improve the administration of justice, promotes programs that assist lawyers and judges in their work, accredits law schools, provides continuing legal education, and works to build public understanding around the world of the importance of the rule of law.

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