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Criminal Tax, Money Laundering, and Bank Secrecy Act Litigation, with 2012 Cumulative Supplement

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An expert analysis of the law and procedure relating to federal criminal cases handled by the IRS and DOJ, addressing the pragmatic and strategic challenges at every stage of litigation  

Main Volume Information

The increase in the scope and complexity of criminal cases handled by the Internal Revenue Service (IRS) and federal prosecutors of the Department of Justice (DOJ) has magnified the need for an examination of the current law, procedure, and practical considerations regarding such cases. Criminal Tax, Money Laundering, and Bank Secrecy Act Litigation provides the critical analysis practitioners need when defending against a federal criminal case pursued by the IRS and DOJ. Covering the entire length of a case from beginning to end, the treatise discusses in detail the entire panoply of complex legal, factual, logistical, and tactical issues raised by such litigation.

Written by a lawyer who has served as both a prosecutor and defense attorney, this treatise provides a comprehensive and current overview of the law and procedure for IRS criminal cases, including investigations, indictment, pretrial practice, plea agreements, trial, and sentencing. This treatise describes how a tax or currency matter that began as a civil issue can turn into a criminal case, as well as the elaborate process for approval or rejection of a proposed tax prosecution. The insights provided in Criminal Tax, Money Laundering, and Bank Secrecy Act Litigation are relevant not to only a wide variety of lawyers such as defense attorneys and corporate counsel, but also to financial institutions, business and tax professionals, and federal government agencies.

Supplement Information

The 2012 Cumulative Supplement includes discussion of: 

  • The government’s high-profile enforcement campaign against undisclosed offshore financial accounts, including the increased investigation and regulation of banks and the 2012 voluntary disclosure program for offshore accounts
  • The government’s increasing willingness to use of evidence gathered by IRS civil personnel to advance criminal tax investigations, and related parallel investigation issues
  • How the receipt of alleged legal fees may result in money laundering charges
  • The new electronic versions of many Bank Secrecy Act reporting forms
  • The evolving definition of “tax loss” under the Federal Sentencing Guidelines, how it may be increased or decreased, and how it can lead to onerous orders of restitution 

Main Volume Information

2010/1,712 pp. Hardcover/Order #9044P

Supplement Information

2012/600 pp. Softcover/ISBN 9781617460449/Order #2044

Main Volume Information

About the Author
Peter D. Hardy is principal in the Philadelphia office of the law firm of Post & Schell PC, where he is part of its national White Collar Defense, Compliance & Risk Management Practice Group. He is a former criminal prosecutor at the Criminal Enforcement Section of the Tax Division of the Department of Justice in Washington, DC, and at the U.S. Attorney’s Office in the Eastern District of Pennsylvania.


Supplement Information

Peter D. Hardy, Author