Check out the co-panelists at the OffhoreAlert Conf

[Demosthenes]

Fighting the IRS

How to Defend Yourself Against an IRS Administrative and Criminal Investigation

Panelists:

Robert G. Bernhoft, Founding Partner, The Bernhoft Law Firm, USA
Edward M. Robbins, Jr., Tax Attorney, Hochman, Salkin, Rettig, Toscher & Perez, USA

Two of the most experienced tax defense attorneys share their tips on defending yourself against a tax investigation. Two of their most notable cases include defending actor Wesley Snipes (Mr. Bernhoft) and UBS client Igor Olenicoff (Mr. Robbins) against criminal actions filed by the IRS.

Among the issues they will look at are: If a criminal investigation target asserts the Fifth Amendment as against a CI request for an interview, or against an administrative summons for books and records, is this "non-cooperation" detrimental to the target's "practical" interest in avoiding a fraud referral and indictment? Even if such "non-cooperation" does, in fact, irritate the CI SAs and give them motive to press hard for indictment approval, what are the pros and cons of providing the very information the SAs will use to make their case and complete their Special Agent's Report?

To cooperate or not cooperate is a very important question with significant implications for how the investigation goes and turns. Our panel will look at Fifth Amendment implications in offshore investigations, including UBS.

Topics will include:

Fifth Amendment protection in foreign courts;
Fifth Amendment protection for foreign documents or foreign persons in American courts (implicating applications for judicial assistance under 28 U.S.C. § 1782 and other "discovery" mechanisms); and
Fifth Amendment protection for foreign entities.

[Famspear]

Wow. Robbins is a reputable tax lawyer.

And Bernhoft is, uh, a lawyer with a reputation.

[Judge Roy Bean]

To cooperate or not cooperate is a very important question with significant implications for how the investigation goes and turns.

Wow. That's really profound.

Our panel will look at Fifth Amendment implications in offshore investigations, including UBS.

OK rich suckers who fell in with the UBS crowd, here's your chance for a few $K to get some outside "non-legal non-advice" advice before you take things up with your own counsel and have to resort to bribes or influence in the right places to keep the investigation from causing undue stress and embarrassment.

Sounds like fun. Where do you sign up?

[LPC]

To cooperate or not cooperate is a very important question with significant implications for how the investigation goes and turns.

Wow. That's really profound.

But that howler was number two on my list.

The #1 howler on my list was this:

Two of their most notable cases include defending actor Wesley Snipes (Mr. Bernhoft) and UBS client Igor Olenicoff (Mr. Robbins) against criminal actions filed by the IRS.

I don't do criminal law, but even I know that criminal actions are not "filed by the IRS."

It may be a technical issue, but it's an issue that shows that the person who wrote the press release didn't really know what they were talking about.

[notorial dissent]

And as I recall, Snipes lost and will eventually go to jail, and the UBS mess is still an ongoing disaster, so this is a somehow a positive draw?

[Judge Roy Bean]

....

I also wonder if the IRS or DoJ will have a plant there, secretly filming, taking names and addresses of attendees, etc.? Just a thought......

Rest assured, they already know who they are.

[Joey Smith]

David Marchant who runs the OffshoreAlert Conference has always had an eclectic mix of speakers, with presenters as varied as Bob Roach from the Senate Subcommittee on Investigations and legendary attorney Jack Blum of BCI fame, on the same panel with offshore tax evader and convicted felon Jerome Schneider.

I guess that there is some sizzle from representing Snipes, even if it ended in a push.

Having said that, most of the people who go to the OffshoreAlert Conference are forensic accountants, court-appointed receivers, and government regulators, so I doubt that B&B will get much business out of it. Notably, B&B have gone to the OffshoreAlert Conferences for years (as has Bill Branscum who posts here occasionally) and have been regular fixtures there, in a sense.

[notorial dissent]

ND keeps using logic which really has no placve in the cloud-cuckoo land in which a person attending this conference dwells.

I know, my one true failing in life, I just can’t not see the logic even when everyone else swears it is something else. Besides, pointing out the obvious is always easier than inventing some convoluted explanation that makes even less sense than what they are trying to explain.

[Joey Smith]

I also wonder if the IRS or DoJ will have a plant there, secretly filming, taking names and addresses of attendees, etc.? Just a thought......

Usually a good half-dozen IRS-CI agents make their way to the conference, introducing themselves as such and mingling with everybody else. Again, upwards of 70% of the attendees are regulators, from everybody from the state attorney general's offices to the FTC to financial services regulators from the offshore havens to compliance principals of major securities firms. Most of the rest are forensic accountants, investigators, professional receivers, etc.

Occasionally, some nutter will make their way into the conference, but not often, and they usually have nobody to talk with while there. Since most of the presentations are of a "how to spot a crook" nature, they would probably be bored senseless.

It's actually a heckuva good conference, and they do videotape most of the major presentations and audiotape the rest.

[.]

Not much danger of the average TP coughing up even $10 to attend any conference, legit or otherwise, never mind $1,695, they already know it all having conducted their exhaustive "self-study" of all possible issues.