Publications
- "Federal Criminal Tax Enforcement,” UNC Tax Institute Speaker Series (2020), 18th Annual NC/SC/GA Tax Section Workshops (2019), ABA 31st Annual National Institute on Criminal Tax Fraud (2014), International Bar Association 12th Transnational Crime Conference (2009), and ABA 23rd Annual National Institute on White Collar Crime (2009).
- “Federal Criminal Tax Enforcement in the USA,” 20th Annual Conference & General Meeting of the International Association of Prosecutors (2015).
- “DOJ and IRS Use ‘Carrot ‘n Stick’ to Enforce Global Tax Laws” (with Jay R. Nanavati), Criminal Justice, Vol. 29, No. 2, Summer 2014.
- "Compete or Enforce?: U.S. Chooses Enforcement of Tax Laws over Competition on Tax Rates" (with Jay R. Nanavati), Business Crimes Bulletin, Vol. 21, No. 2, October 2013.
- “Privileged Communications and the One-Sided Nature of Crime-Fraud Litigation” (with Jeffrey A. Neiman), Business Crimes Bulletin, Vol. 18, No. 11, July 2011.
- "Government Searches of Computers" (with William A. Whitledge), Business Crimes Bulletin, Vol. 17, No. 12 (August 2010).
- "Tax Crimes: Has the Bright Line Moved?" (with Scott D. Michel), Business Crimes Bulletin, Vol. 15, No. 6, February 2008.
- "Complaints of Judicial Misconduct," Business Crimes Bulletin, Vol. 14, No. 7 March 2007.
- "New Agreements with Europe on Extradition and Mutual Legal Assistance," Business Crimes Bulletin, Vol. 13, No. 2, October 2005.
- "The IRS Office of Professional Responsibility: What Responsible Professionals Need to Know" (with Scott D. Michel), Business Crimes Bulletin, Vol. 11, No. 11, December 2004.
- "The War on Judicial Sentencing Discretion: What Corporate Counsel Needs to Know" (with Mark H. Allenbaugh), Business Crimes Bulletin, Vol. 11, No. 4, May 2004.
- "Avoiding Criminal Tax Prosecution of the Client with Foreign Accounts: An Analysis of the IRS Offshore Voluntary Compliance Initiative," Business Crimes Bulletin, Vol. 10, No. 7, August 2003.
- "Dealing with the Media and with Professionals as Clients: A U.S. Perspective," International Law Practitioner, Vol. 28, No. 2, July 2003.
- "Avoiding Criminal Tax Prosecution: The Newly Revised IRS Voluntary Disclosure Policy," Business Crimes Bulletin, Vol. 9, No. 12, January 2003.
- "Money Laundering, Fraud, and the Three Dimensions of Chapter 3(D) of the Federal Sentencing Guidelines" (with Mark H. Allenbaugh), 49 Federal Lawyer 38 (2001).
- “Taking Smaller Bytes Protects Constitutional Rights: Addressing the Novel Problem Posed by Deleted Data” (with Mark H. Allenbaugh), ABA National Institute on White Collar Crime (2001).
- "Apprendicitis: A Troubling Diagnosis for the Sentencing of Hackers, Thieves, Fraudsters, and Tax Cheats" (with Mark H. Allenbaugh), 9 Geo.Mason L.Rev. 419 (2000), cited by the U.S. Court of Appeals for the Sixth Circuit in Cvijetinovic v. Eberlin, No. 08-3629, 2010 W.L. 329970, note 5 (6th Cir. 2010).
- "Conundrum in the Caymans: Unilateral Tax Enforcement Presents a New Challenge to Foreign Sovereignty and Constitutional Due Process" (with Mark H. Allenbaugh), International Bar Association, 1999 Business Law Conference in Barcelona, Spain; republished for ABA National Institute on White Collar Crime (2000).
- "Obtaining Evidence from the United States of America" (with Bernard S. Bailor), International Association of Prosecutors, 1998 Annual Conference, Dublin, Ireland, and republished for ABA National Institute on Criminal Tax Fraud (2001) and IBA 8th Transnational Crime Conference in Milan, Italy (2005).
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Areas of Practice
- White Collar Crime with emphasis on Tax Fraud and Business Crimes
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