Publications
"Tax Fraud Enforcement: A United States Perspective," International Bar Association 12th Transnational Crime Conference (2009).
"Federal Criminal Tax Enforcement," ABA 23rd Annual National Institute on White Collar Crime (2009) & ABA 25th Annual National Institute on Criminal Tax Fraud (2008).
"Tax Crimes: Has the Bright Line Moved?," Business Crimes Bulletin, Vol. 15, No. 6, February 2008.
"Complaints of Judicial Misconduct," Business Crimes Bulletin, Vol. 14, No. 7 March 2007.
"New Agreements with Europe on Extradition and Mutual Legal Assistance," Business Crimes Bulletin, Vol. 13, No. 2, October 2005.
"The IRS Office of Professional Responsibility: What Responsible Professionals Need to Know," Business Crimes Bulletin, Vol. 11, No. 11, December 2004.
"The War on Judicial Sentencing Discretion: What Corporate Counsel Needs to Know," Business Crimes Bulletin, Vol. 11, No. 4, May 2004.
"Avoiding Criminal Tax Prosecution of the Client with Foreign Accounts: An Analysis of the IRS Offshore Voluntary Compliance Initiative," Business Crimes Bulletin, Vol. 10, No. 7, August 2003.
"Dealing with the Media and with Professionals as Clients: A U.S. Perspective," International Law Practitioner, Vol. 28, No. 2, July 2003.
"Avoiding Criminal Tax Prosecution: The Newly Revised IRS Voluntary Disclosure Policy," Business Crimes Bulletin, Vol. 9, No. 12, January 2003.
"Money Laundering, Fraud, and the Three Dimensions of Chapter 3(D) of the Federal Sentencing Guidelines," 49 Federal Lawyer 38 (2001).
"Apprendicitis: A Troubling Diagnosis for the Sentencing of Hackers, Thieves, Fraudsters, and Tax Cheats," 9 Geo.Mason L.Rev. 419 (2000).
"Conundrum in the Caymans: Unilateral Tax Enforcement Presents a New Challenge to Foreign Sovereignty and Constitutional Due Process," International Bar Association, 1999 Business Law Conference in Barcelona, Spain; republished for ABA National Institute on White Collar Crime (2000).
"Guideline Sentencing in Tax Fraud Cases: Recent Developments in Calculating Tax Loss," ABA National Institute on White Collar Crime (1999).
"Obtaining Evidence from the United States of America," International Association of Prosecutors, 1998 Annual Conference, Dublin, Ireland, and republished for ABA National Institute on Criminal Tax Fraud (2001).
"Lawyers Under Attack: The Expanding Assertion of the Crime-Fraud Exception to the Attorney-Client Privilege," 9th Annual Seminar on White Collar Crime, Institute of Continuing Legal Education in Georgia (1998).
"Representing a Taxpayer before the Criminal Investigation Division Arrives," ABA National Institute on Criminal Tax Fraud (1997).
"Criminal Tax Fraud: Keeping Your Client (and Yourself) Out of Jail," 7th Annual Seminar on White Collar Crime, Institute of Continuing Legal Education in Georgia (1996).
"May a Foreign National Successfully Assert a Fifth Amendment Claim for Fear of Foreign Prosecution," International Enforcement Law Reporter, Vol. 10, Issue 9, September 1994.
"Crime Doesn't Pay - But Counsel May: Criminal Exposure in the Everyday Practice of Law," Criminal Justice, Vol. 8, No.3 Fall 1993; republished in Corporate Counsel's Quarterly, Vol 10, No. 1, January 1994.