Using Extended FTC S/L to Defend Against Tax Evasion Charges
Tax Partner Andrew Weinstein authored a WG&L Journal Previews article titled "Using Extended FTC S/L to Defend Against Tax Evasion Charges."
Mr. Weinstein discusses a recent development relevant to a March 2010 Journal of Taxation article titled "Foreign Tax Credits: Can a Deficiency Be Retroactively Wiped Out for Criminal Tax Evasion Purposes?," which he co-authored. In the previous article, Mr. Weinstein and his co-author suggested that the Section 901 foreign tax credit (FTC) is available as a defense to a prosecution for federal income tax evasion. In the WG&L Journal Previews article, Mr. Weinstein discusses how the recent United States v. Carolynne Tilga and Michael Chandler, in which Mr. Weinstein represented the defendant, has affected this area.