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
Long Arm of the Law
The risk to U.S. practitioners of prosecution for facilitating foreign tax offenses.