On December 13, 2013, the United States Court of Appeals for the Fourth Circuit issued its decision in United States of America v. Under Seal, a copy of which is available here. […]
https://fidjlaw.com/wp-content/uploads/2007/02/FIDJ-Logo-Hero.svg00admin_fidjhttps://fidjlaw.com/wp-content/uploads/2007/02/FIDJ-Logo-Hero.svgadmin_fidj2014-01-29 10:26:552026-01-07 15:14:00Criminal Tax Litigation Update: Courts are Consistently Ruling that the Act of Production Privilege Will Not Defeat Grand Jury Subpoenas Calling for Foreign Bank Account Statements
On January 23, 2014, the Consumer Financial Protection Bureau (“CFPB”) issued a proposed rule that would extend its regulatory authority to certain nonbank international money transfer providers. A copy of CFPB’s press […]
https://fidjlaw.com/wp-content/uploads/2007/02/FIDJ-Logo-Hero.svg00admin_fidjhttps://fidjlaw.com/wp-content/uploads/2007/02/FIDJ-Logo-Hero.svgadmin_fidj2014-01-27 16:20:372026-01-06 10:05:25CFPB Proposes To Regulate Large International Money Transfer Providers
On November 14, 2013, the United States Court of Appeals for the Second Circuit clarified the standard of review for mixed questions of law and fact in a case on […]
https://fidjlaw.com/wp-content/uploads/2007/02/FIDJ-Logo-Hero.svg00admin_fidjhttps://fidjlaw.com/wp-content/uploads/2007/02/FIDJ-Logo-Hero.svgadmin_fidj2014-01-23 12:02:012025-12-10 14:32:43Tax Litigation Update: Second Circuit Tweaks its Standard of Review in Tax Cases Involving Mixed Questions of Law and Fact; Decides Complex Tax Controversy Involving “Midco†Transaction
Last month, we wrote about the uncertainty in choosing the proper appeals court in certain Tax Court cases, and described the rift between the First, Eighth and Ninth Circuits on the one […]
https://fidjlaw.com/wp-content/uploads/2007/02/FIDJ-Logo-Hero.svg00admin_fidjhttps://fidjlaw.com/wp-content/uploads/2007/02/FIDJ-Logo-Hero.svgadmin_fidj2014-01-22 11:50:012025-12-10 14:38:27Tax Litigation Update: The D.C. Circuit is the Proper Venue for Many Appeals of Tax Court Cases
INTRODUCTION AND BACKGROUND It is a bedrock principle of tax litigation that the US Tax Court is bound to following the precedent of the Circuit Court of Appeals to which […]
https://fidjlaw.com/wp-content/uploads/2007/02/FIDJ-Logo-Hero.svg00admin_fidjhttps://fidjlaw.com/wp-content/uploads/2007/02/FIDJ-Logo-Hero.svgadmin_fidj2013-12-16 15:10:402025-12-10 14:30:49Tax Litigation Update: Determination Of Proper Appellate Court For Review Of Certain Tax Court Cases In Flux
Los Angeles Businessman, David Raminfard, pleaded guilty on November 4th, 2013 in the Federal District Court in Los Angeles to conspiring to defraud the United States, the Justice Department and […]
https://fidjlaw.com/wp-content/uploads/2007/02/FIDJ-Logo-Hero.svg00admin_fidjhttps://fidjlaw.com/wp-content/uploads/2007/02/FIDJ-Logo-Hero.svgadmin_fidj2013-12-13 11:10:272025-12-10 14:28:41Raminfard Guilty Plea Highlights Complexity Of International Tax Compliance, Seriousness Of Violations, Importance Of Irs Offshore Voluntary Disclosure Program
The Carmack Amendment to the Interstate Commerce Act established a uniform national policy for interstate carriers’ liability for property loss. 49 U.S.C. § 14706. Under Carmack, while a carrier is […]
The art of communication has changed considerably over the past few years. Rather than in-person or telephonic, the majority of communications in today’s business world are electronically transmitted. Likewise, professional […]
https://fidjlaw.com/wp-content/uploads/2007/02/FIDJ-Logo-Hero.svg00admin_fidjhttps://fidjlaw.com/wp-content/uploads/2007/02/FIDJ-Logo-Hero.svgadmin_fidj2013-12-04 15:52:432014-11-10 18:08:29Litigation Update – The Electronic Loss of Privilege
On November 13, 2013, the United States District Court for the Middle District of Florida granted partial summary judgment in favor of the United States inUnited States ex rel. Baklid-Kunz […]
https://fidjlaw.com/wp-content/uploads/2007/02/FIDJ-Logo-Hero.svg00admin_fidjhttps://fidjlaw.com/wp-content/uploads/2007/02/FIDJ-Logo-Hero.svgadmin_fidj2013-12-03 10:15:172014-11-10 18:08:29False Claims Act Litigation Update: Florida Federal Court Finds Hospital Violated Stark Law Via Oncologist Bonus Compensation System
Under Internal Revenue Code (hereinafter “IRC” or “Code”) § 6013(d)(3), spouses who file joint tax returns are jointly and severally liable for all tax due and owing for the tax […]
https://fidjlaw.com/wp-content/uploads/2007/02/FIDJ-Logo-Hero.svg00admin_fidjhttps://fidjlaw.com/wp-content/uploads/2007/02/FIDJ-Logo-Hero.svgadmin_fidj2013-11-22 16:18:442025-12-16 08:51:58IRS Makes Significant Changes to Innocent Spouse Relief
Criminal Tax Litigation Update: Courts are Consistently Ruling that the Act of Production Privilege Will Not Defeat Grand Jury Subpoenas Calling for Foreign Bank Account Statements
On December 13, 2013, the United States Court of Appeals for the Fourth Circuit issued its decision in United States of America v. Under Seal, a copy of which is available here. […]
CFPB Proposes To Regulate Large International Money Transfer Providers
On January 23, 2014, the Consumer Financial Protection Bureau (“CFPB”) issued a proposed rule that would extend its regulatory authority to certain nonbank international money transfer providers. A copy of CFPB’s press […]
Tax Litigation Update: Second Circuit Tweaks its Standard of Review in Tax Cases Involving Mixed Questions of Law and Fact; Decides Complex Tax Controversy Involving “Midco†Transaction
On November 14, 2013, the United States Court of Appeals for the Second Circuit clarified the standard of review for mixed questions of law and fact in a case on […]
Tax Litigation Update: The D.C. Circuit is the Proper Venue for Many Appeals of Tax Court Cases
Last month, we wrote about the uncertainty in choosing the proper appeals court in certain Tax Court cases, and described the rift between the First, Eighth and Ninth Circuits on the one […]
Tax Litigation Update: Determination Of Proper Appellate Court For Review Of Certain Tax Court Cases In Flux
INTRODUCTION AND BACKGROUND It is a bedrock principle of tax litigation that the US Tax Court is bound to following the precedent of the Circuit Court of Appeals to which […]
Raminfard Guilty Plea Highlights Complexity Of International Tax Compliance, Seriousness Of Violations, Importance Of Irs Offshore Voluntary Disclosure Program
Los Angeles Businessman, David Raminfard, pleaded guilty on November 4th, 2013 in the Federal District Court in Los Angeles to conspiring to defraud the United States, the Justice Department and […]
Florida Business Litigation Update: The Carmack Amendment Preempts Virtually Everything
The Carmack Amendment to the Interstate Commerce Act established a uniform national policy for interstate carriers’ liability for property loss. 49 U.S.C. § 14706. Under Carmack, while a carrier is […]
Litigation Update – The Electronic Loss of Privilege
The art of communication has changed considerably over the past few years. Rather than in-person or telephonic, the majority of communications in today’s business world are electronically transmitted. Likewise, professional […]
False Claims Act Litigation Update: Florida Federal Court Finds Hospital Violated Stark Law Via Oncologist Bonus Compensation System
On November 13, 2013, the United States District Court for the Middle District of Florida granted partial summary judgment in favor of the United States inUnited States ex rel. Baklid-Kunz […]
IRS Makes Significant Changes to Innocent Spouse Relief
Under Internal Revenue Code (hereinafter “IRC” or “Code”) § 6013(d)(3), spouses who file joint tax returns are jointly and severally liable for all tax due and owing for the tax […]