Publications
-Quoted in USA Today, “IRS Unlikely to Pursue Tax Fraud Allegations Against Donald Trump and Family, Experts Say,” October 3, 2018
-Moderator, “Anti-Money Laundering Compliance Conference, IRS Investigations by the Department of Justice in the United States” at Panama Bankers Association Convention, August 15-19, 2016, Hard Rock Hotel Panama Megapolis, Panama
-Interviewed by WLRN- NPR by Tim Padgett about “Sunset Mansions Vs. Sunshine Laws: Do Shell Companies Darken Florida’s Image?,” April, 19, 2016
-Quoted in USA Today, “Panama Papers Firm Linked to Over 1,000 U.S. Companies,” April 7, 2016
-Quoted in Daily Business Review, “Curacao Stock Exchange Seeks International Startups,” March 30, 2016
-Quoted in Tax Notes Today, “Practitioners, DOJ Debate 8th Amendment FBAR Applicability,” October 13, 2015
-The American Law Institute CLE, Washington, D.C., October 9, 2015, “Litigating FBAR and Fraud Penalties in U.S. District Court and CFC”
-Moderator, “Memories Fade But Emails are Forever: New Electronic Discovery Rules in US Tax Court” at American Bar Association Section of Taxation meeting, May 7-9, 2015, Washington, DC
-FIBA Anti Money Laundering Compliance Conference “Cross-Border Income Tax Investigations of Bank Customers” March 6, 2015, Miami, FL
-Co-author “FBAR Penalties and U.S. v. Zwerner” International Tax Journal, 2015
-“The 2014 Tax Person of the Year,” 2015 Tax Notes Today 2-1, 2015
-University of San Diego, School of Law Procopio International Tax Institute “Some Open Issues In Streamlined Program” San Diego, CA, October 30 & 31, 2014
-Co-author “Plausible Inference Test” Journal of Tax Practice & Procedure, 2014
-The 6th Annual Tax Controversy Forum, New York, NY, June 20, 2014, “But This Is Just a Fishing Expedition! Contesting IRS Summonses”
-The 30th Annual National Institute on Criminal Tax Fraud and the Third Annual National Institute on Tax Controversy, Las Vegas, NV, December 13, 2013, “Defending Taxpayer Penalties”
-ABA Section of Taxation, Orlando, FL, 2013 Midyear Meeting – January 26, 2013, “Identity Theft: Issues for the Tax Practitioner and the Taxpayer”
-The 29th Annual National Institute on Criminal Tax Fraud and the Second Annual National Institute on Tax Controversy, Las Vegas, NV, December 6th, 2012, “Effectively Settling a Cast at Exam, Appeals or in Court”
-The Heckerling Institute on Estate Planning, Orlando, FL, January 13, 2011
-ABA Section on Taxation, Boca Raton, FL, 2011 Midyear meeting – January 20-22, 2011, -“Smokin’ Hot Issues in IRS Enforcement” and “Voluntary Disclosure to the IRS Employment Taxes”
-Opal Trust, Tax and Estate Planning Forum, New York City, March 17, 2011, “Government Taxation & Regulation: What Are the Current Changes and How Do We Deal with Them?”
-IRS Internal Estate & Gift Tax Attorneys – CPE, Tampa, FL, August 10-11, 2011, “Hidden Offshore Assets – What Is the Ethical Practitioner to Do?”
-Panama Banker’s Association, Panama City, Panama, August 25, 2011, “How the Panamanian Banks Must Reduce Their Risks Associated with FATCA Understanding the Individual and Institutional Liabilities and Responsibilities”
-Quoted in Tax Notes Today about “Practitioners, DOJ Debate 8th Amendment FBAR Applicability,” October 13, 2015
-Quoted in Tax Notes Today, “2015 TNT 149-3 BUSH REMARKS REASSURE NORQUIST; TRUMP TRIES TO PAY LITTLE TAX,” August, 03, 2015
-Quoted in Daily Tax Report, “Tough Scrutiny of Taxpayers Seeking Streamlined OVDP Expected in 2015,” January 26, 2015
-Quoted in South Florida Business Journal about “What Obama’s State of the Union tax announcements mean for South Florida’s ultra-rich,” January 23, 2015
-Quoted in BNA Daily Tax Report, “Questions Surround Standards of Willful Conduct Under Streamlined OVDP,” September 18, 2014
-Quoted in Daily Business Review, “Feds Were “Outlawyered” in UBS Case, Experts Say,” November 4, 2014
-Quoted in BNA Daily Tax Report, “Experts Welcome Guidance on Streamlined OVDP, Say Willful Conduct Framework Needed,” October 14, 2014
-Quoted in BNA Daily Tax Report, “Questions Surround Standards of Willful Conduct Under Streamlined Version of OVDP,” September, 2014
-Quoted in BNA Daily Tax Report, United States v. Clarke – “Supreme Court Gives Taxpayer Standard to Challenge IRS Summonses for Bad Faith,” June 19, 2014
-Quoted in Daily Business Review, “Real Estate Deals Delayed: Blame the IRS,” March 19, 2014
-Quoted in Bloomberg about “Swiss Banks Seek Tax Amnesty as Third Accept U.S. Offer,” January 26, 2014
-Quoted in USA Today, “Swiss Banks Closer to Details in Tax Evasion Probe,” January 25, 2014
-Quoted in Daily Business Review, “Swiss Banks Seek to Join U.S. Tax Amnesty Program,” January, 2014
-Quoted in Bloomberg News about “Ex-UBS Banker Weil Seen Cooperating With Prosecutors,” December 16, 2013
-Quoted in USA Today about “When They Were Rich: Madoffs’ ’04 Tax Return,” December 13, 2013
-Interviewed by BBC Business Matters, London, England about “Switzerland Weighs U.S. Tax Deal to End Dispute,” May 30, 2013
-Quoted in USA Today about “Switzerland Weighs U.S. Tax Deal to End Dispute,” May 29, 2013
-Interviewed by USA Today about “Advocate: IRS Does Poor Job on Identity Theft,” January 9, 2013
-Quoted in Daily Business Review about “Tribe Dealt Another Blow,” October 16, 2012
-Quoted in South Florida Business Journal about “Will Election Affect Offshore Tax Evasion Crackdown?” October 12, 2012
-Quoted in USA Today about “Romney Releases Taxes, Claims He Has Paid Every Year,” September 22, 2012
-Quoted in CNN Money about “Romney Paid 14% Effective Tax Rate in 2011,” September 21, 2012
-Quoted in Daily Business Review about “UBS Whistle-blower to Get Record $104 Million from IRS,” September 12, 2012
-Quoted in Tax Notes Today about “No Anomalies Apparent in Ryan Return, ” August 21, 2012
-Quoted in Daily Business Review about “Feds Get Lift Against Offshore Holders,” August 13, 2012
-Quoted in Daily Business Review about “For Tax Reasons, Wealthy Reconsider Citizenship” and “Campaign Finance Legal Influence,” June 4, 2012
-Quoted in Tax Analysts Tax Notes Today about “Obamas Pay 20.5 Percent Federal Tax Rate,” April 16, 2012
-Interviewed by Marketplace Money about “Home Business Tax Dodgers Beware!” April 7, 2012
-Interviewed by Swiss National Media Television about “Switzerland-USA Tax Agreement: the United States, Investigations Continue Against Tax Evaders,” February 2012 and subsequent follow-up interview March 29, 2012
-Quoted in Daily Business Review about “Justice Department Broadens War on Tax Evaders,” March 26, 2012
-Quoted in Tax Analysts Tax Notes Today about “Santorum Releases Tax Returns, Showing 28 Percent Effective Rate,” February 17, 2012
-Quoted in Palm Beach Daily News about “Capital Gains Key to Romney Tax Strategy,” January 29, 2012
-Quoted in Tax Analysts Tax Notes Today about “Romney’s Returns Could Jump Start Carried Interest Debate,” January 25, 2012
-Quoted in USA Today about “Gingrich’s Taxes Raise Red Flag,” January 24, 2012
-Quoted in USA Today about “Romney Confirms He Gets a Big Tax Break,” January 18, 2012
-Interviewed by Marketplace Money about “What Millionaires Pay in Taxes,” January 16, 2012
-Quoted in Daily Business Review about “Lawmakers Decry Proposed Change to IRS Rules,” November 21, 2011
-Quoted in South Florida Business Journal about “Regulations Pose Problems for Many South Florida Companies,” September 30, 2011
-Quoted in Daily Business Review about “Homebuyer Credit Plan Was Ripe for Abuse,” August 22, 2011
-Interviewed by the Swiss media about US v. UBS, Swiss National Media Television, May 11, 2011
-Interviewed by Fox Business News about “Breaking Down the Changes in Estate Tax Law,” May 4, 2011
-Quoted in Daily Business Review about “Best Bank Holdups Are Done with Pen, Not Gun,” January 24, 2011
-Interviewed by Fox Business News on “Giving Tips for Preparing Your Wallet for Tax Increases,” July 9, 2010
-Interviewed by Brian Ross on ABC Nightly News about “IRS Voluntary Disclosure Program,” October 12, 2009
-Quoted on tax issues in Time Magazine, USA Today, New York Times, Wall Street Journal, Bloomberg, BBC World, National Public Radio and German National Radio