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Fifth Amendment – Privilege against self-incrimination

Another Circuit says IRS can compel production of foreign bank records

Another Circuit says IRS can compel production of foreign bank records

Chabot, (CA 3 7/17/2015) 116 AFTR 2d ¶ 2015-5060 The Court of Appeals for the Third Circuit, affirming a district court decision, has held that the “required records” exception to the Fifth Amendment privilege against self-incrimination applies to allow IRS to summon foreign bank account records. This is the same conclusion arrived at by the […]

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IRS Targets U.S. Tax Cheats by Summoning Records from Shipping and Financial Service Providers

IRS Targets U.S. Tax Cheats by Summoning Records from Shipping and Financial Service Providers

Click here to view the DOJ press release dated Dec. 19, 2014. Click here to view the “[Proposed] Order Granting Ex Parte Petition for Leave to Serve “John Doe” Summonses.” A U.S. district court has authorized IRS to serve “John Doe” summonses to eight entities in the shipping and financial services industries in order to identify the […]

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Required Records Doctrine compelled production of foreign bank records

Required Records Doctrine compelled production of foreign bank records

Editor’s Note:  this reported case is important in the context of representation of clients under “criminal investigation.”  In brief, the Seventh Circuit Court of Appeals, follows the Ninth Circuit Court of Appeals (for taxpayers here in California and several other states), and holds that the Fifth Amendment privilege against self-incrimination couldn’t be used by a […]

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Case Alert: Ninth Circuit Disagrees with District Court – – Warrantless Search is Violation of 4th Amendment

Case Alert:  Ninth Circuit Disagrees with District Court – – Warrantless Search is Violation of 4th Amendment

Editor’s Note:  most reported cases these days (and it seems in the past few years), have been tough on criminal defendants.  Occasionally, lower courts come out with favorable decisions, and sometimes unfavorable decisions are reversed by Courts of Appeal.  Here in California, the Ninth Circuit Court of Appeals governs the law of the land so-to-speak, […]

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Meet Paul Raymond

Meet Paul Raymond

Mr. Raymond is a sought after speaker in tax controversy law by many attorney, accountant, and business groups and at the request of the Internal Revenue Service, has presented programs at the IRS Nationwide Tax Forum, attended by tax professionals throughout the United States.

Additionally, he continues to be an active member in the Section of Taxation, American Bar Association, where he was the Past Chair of the Employment Taxes Committee.

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Member CA Bar Member Orange County Bar US Tax Court Attorney