convoker percy green llp: Stamford CT IRS Criminal Tax: Fifth Amendment Privilege Held to be Inapplicable to Subpoena for Foreign Bank Records Required under Bank Secrecy Act - 12/07/11 08:50 PM
We represent taxpayers in IRS Criminal tax investigations frequently, and often deal with foreign bank account issues in Stamford, Connecticut as well as elsewhere in New England.  In In re Grand Jury Investigation M.H. v. United States, 648 F.3d 1067 (9thCir.2011), the Ninth Circuit held that foreign bank account records required to be kept under the Bank Secrecy Act (“BSA”) fall within the Required Records Doctrine, thus rendering the Fifth Amendment privilege against self-incrimination inapplicable to a subpoena for these records.
When I am asked by clients about records demanded by the government, I often have to explain that records required … (0 comments)

 
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