Recent years have seen an increase in U.S. enforcement actions against tax advisors, bankers and other “enablers” for assisting clients and customers in evading taxes, including non-U.S. advisors whose activities were largely offshore. Most U.S. enforcement actions have focused on federal tax compliance. However, there’s growing concern among practitioners that the U.S. government may take a closer look at the potential role of U.S. tax and estate-planning lawyers who
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