Peter D. Hardy
Marjorie J. Peerce

The 33rd Annual National Institute on Criminal Tax Fraud is the annual gathering of the criminal tax defense bar combined with the Sixth Annual National Institute on Tax Controversy. This program brings together high-level government representatives, judges, corporate counsel, and private practitioners engaged in all aspects of tax controversy, tax litigation, and criminal tax prosecutions and defense. Ballard Spahr partners Marjorie J. Peerce and Peter D. Hardy will each speak during the breakout sessions.

The Next Wave: The Government’s Focus on U.S. Investments to Evade Foreign Taxes
Thursday, December 8, 2016 | 2:20 PM – 3:20 PM

There is increasing attention to the use of U.S. investments, structures, and bank accounts to facilitate tax evasion in other countries. The last year has seen a number of initiatives to increase information reporting concerning these activities, as well as increased investigations in this area. Ms. Peerce will join other panelists to discuss these initiatives, the tools available to the government, and ways to be prepared for the next wave of enforcement.

Offshore Enforcement: How Will They Prove It?
Thursday, December 8, 2016 | 3:35 PM – 4:25 PM

The examination is over and the IRS has determined that an FBAR penalty will be assessed against the taxpayer. Not every case can be settled at appeals, and the number of new cases being filed by Department of Justice is increasing rapidly. The government has used many tools to formally and informally obtain information about offshore banking activity. Mr. Hardy will join panelists from the government and defense bar to discuss the unique issues associated with preparing a FBAR case for trial.

Please click here for more information or to register. Attendees can earn up to 14.75 CLE credit hours (including 2.25 Ethics credits).