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Practice Tip: Tax Liabilities
Divorce can often devolve into economic warfare. For some people, tax issues ' through neglect, naivet', or as a result of an asset liquidation or distribution ' create tax liabilities for which they were unprepared. As a result, it is not uncommon for divorce litigants to require tax liability mitigation.
It was with this in mind that I skeptically listened to a radio commercial for the IRS's “Fresh Start” tax relief program. The celebrity pitchman was extolling the virtues of this program on behalf of a tax relief company. My initial response to this ad was that it was probably a predatory program, but after doing some research, I learned that it is a legitimate program offered by the IRS. The basic premise of the program is to give delinquent taxpayers (including small businesses) an incentive to enter into an offer in compromise with the IRS to pay their back-taxes.
The DOJ's Corporate Enforcement Policy: One Year Later
The DOJ's Criminal Division issued three declinations since the issuance of the revised CEP a year ago. Review of these cases gives insight into DOJ's implementation of the new policy in practice.
The DOJ's New Parameters for Evaluating Corporate Compliance Programs
The parameters set forth in the DOJ's memorandum have implications not only for the government's evaluation of compliance programs in the context of criminal charging decisions, but also for how defense counsel structure their conference-room advocacy seeking declinations or lesser sanctions in both criminal and civil investigations.
Use of Deferred Prosecution Agreements In White Collar Investigations
This article discusses the practical and policy reasons for the use of DPAs and NPAs in white-collar criminal investigations, and considers the NDAA's new reporting provision and its relationship with other efforts to enhance transparency in DOJ decision-making.
A Lawyer's System for Active Reading
Active reading comprises many daily tasks lawyers engage in, including highlighting, annotating, note taking, comparing and searching texts. It demands more than flipping or turning pages.
Bankruptcy Sales: Finding a Diamond In the Rough
There is no efficient market for the sale of bankruptcy assets. Inefficient markets yield a transactional drag, potentially dampening the ability of debtors and trustees to maximize value for creditors. This article identifies ways in which investors may more easily discover bankruptcy asset sales.