Monthly Archives: December 2014

EVALUATING RISK OF PROSECUTION OUTSIDE OF THE OVDP

Posted on December 10, 2014 by taxpenaltylawyer

An article authored by Edward Robbins, Jr. Steven Toscher and Dennis Perez, “What’s Your Client’s Criminal Exposure on His Undeclared Foreign Bank Account? (Journal of Tax Practice, October – November 2012 pp 67-74), astutely summarizes the most likely charged tax … Continue reading →

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THERE’S NOTHING CIVIL ABOUT THE STREAMLINED FILING PROCESS

Posted on December 2, 2014 by taxpenaltylawyer

Many believe that you can bifurcate the Streamlined Process between the criminal aspect and civil aspect.  That once you have a non-willful opinion from the criminal tax lawyer, the process becomes civil and any competent civil tax lawyer or tax … Continue reading →

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