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This comes after our post "Fifth Amendment Does Not Apply to Offshore Banking Records," where we discuss that under the Required Records Doctrine, and a taxpayer who is the subject of a grand jury investigation into his use of offshore bank accounts cannot invoke the privilege to resist compliance with a subpoena seeking records kept pursuant to the Bank Secrecy Act, the U.S. Court of Appeals for the Seventh Circuit ruled Aug. 27 (In re Special February 2011-1 Grand Jury Subpoena Dated September 12, 2011, 7th Cir., No. 11-3799, 8/27/12).
Now the Supreme Court
has declined to review a decision of the Court of Appeals for the Third Circuit
which held that the "required records" exception to the Fifth
Amendment privilege against self-incrimination applies to allow IRS to summon
foreign bank account records. (See Chabot, 577 U.S. 15-454, cert denied 11/30/2015).
Do You Have Undeclared Income from an Offshore Bank?
Want to Know if the OVDP Program is Right for You?
Contact the Tax Lawyers at
Marini& Associates, P.A.
for a FREE Tax Consultation
Toll Free at 888-8TaxAid (888) 882-9243
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