Niles Elber to Speak at ABA Criminal Tax Fraud and Tax Controversy 2012 Meeting
Program: Revisiting the Sensitive Audit in an Era of Greater Financial Transparency
Event Sponsor: American Bar Association
On Thursday, December 6, 2012, Niles A. Elber will take part in a panel discussion entitled "Revisiting the Sensitive Audit in an Era of Greater Financial Transparency." The program will be from 4:15 PM to 5:30 PM at the Wynn Las Vegas. For more information, please go to the American Bar Association's website.
Numerous IRS examinations have been commenced for non-participating Offshore Voluntary Disclosure Initiative taxpayers as a result of treaty disclosures, whistleblowers, cooperators, country-wide settlement discussions, and other sources for bank and financial information worldwide. These examinations are anything but routine and can easily expand to include other account-holders. How should a representative respond to demands to interview the taxpayer? What happens if the taxpayer declines an interview request by claiming the protections afforded by the Fifth Amendment? What advice can you provide regarding the filing of current tax and information returns? How can you determine what information triggered the examination? Will a FOIA request provide meaningful information?