5th Circuit Reverses Conviction to Have Court Calculate the Foreign Evidence Request Final Action for Statute of Limitations Suspension and, Properly Instructed, Have Jury Determine Whether Criminal Act Occurred in Statute of Limitations as Suspended (1/13/22)
3rd Circuit Rejects Argument to Extend Marinello Pending Proceeding Requirement for Tax Obstruction to the Defraud Klein Conspiracy (1/10/22)
Court Enters Stipulated Order to Prevent Alienation of Swiss Account Holdings (12/27/21)
FinCEN Adopts Immediately Effective Final Rule Omitting the Regulations Statement of the 2004 Willful Penalty Prior to the 2004 Statutory Amendment (12/26/21)
District Court for ED VA Dismisses Reverse False Claims Act Proceeding Against Credit Suisse (12/22/21)
Fifth Circuit Affirms Defendant's Waiver of Counsel Conflict of Interest and Punts on Ineffective Assistance of Counsel Claim on Direct Appeal (12/10/21)
Fifth Circuit Applies FBAR NonWillful Penalty Per Account and Not Per Form (11/30/21)
Civil Liability for Conduct that is Acquitted in Criminal Case (11/20/21)
District Court holds (1) FBAR Penalty Statute of Limitations is Waivable and (2) FBAR Nonwillful Penalty is Per Account (11/8/21)
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