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Posts in January, 2015

  • Jan 25 The Definition of Willfulness in OVDP and Streamlined Cases

    Last Updated: January 15, 2019 What constitutes “willful” in determining the meaning of the term “non-willful” as used by the ...

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  • Jan 21 Global Tax Enforcement - Another Example of Why You Need a Tax Attorney

    On October 20, 2014, Menashe Cohen pleaded guilty in New Hampshire federal court to one count of filing a false income tax return ...

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  • Jan 02 Fifth Amendment Protection for Your Offshore Bank Records?

    One of the most frequent questions I get from private clients is whether they can assert their Fifth Amendment Right to Avoid ...

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  • Jan 02 Switzerland and China Sign New Income Tax Treaty

    Switzerland and China have signed a new Income and Capital Tax Treaty that, once in force and effective, will replace the old ...

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