LAW 505 - Federal Tax Crimes & Penalties

Unit(s): 2

This course provides an overview of federal tax crimes and civil penalties. The course is designed to teach students how to represent a client, who is the subject of a civil examination or criminal investigation and facing potential civil penalties or tax crimes. Congress established severe civil and criminal penalties for individuals who fail to report and pay tax on their income or file returns. The course provides students with practical skills and strategies that can be used to represent a client before the Internal Revenue Service. The course covers, for example, tax fraud, the IRS criminal investigation process, government information gathering tools through the use summons and subpoenas, commonly charged tax crimes, taxpayer defenses, sentencing guidelines, international tax enforcement with respect to foreign source income and undisclosed foreign financial assets, the Bank Secrecy Act, Foreign Account Tax Compliance Act, IRS voluntary disclosure practice, Fifth Amendment privilege against self-incrimination, attorney-client privilege, and civil tax penalties. The course is taught through weekly homework assignments, where students will learn how to critically analyze a tax controversy fact pattern, identify the issues, and formulate a case strategy and solution for the client.

Restriction: College restricted to School of Law
School of Law