Joseph A. Rillotta and Luis R. Then wrote an article for TaxNotes “The Rarely Used Tax Fraud Theory Behind a Guyanese Politician’s Indictment”

In their new article with TaxNotes, “DOJ Wields a Rarely Used Tax Fraud Theory to Indict a Controversial Guyanese Politician,” firm attorneys Joseph A. Rillotta and Luis R. Then examine the U.S. Department of Justice’s prosecution of Guyanese political figure Azruddin Mohamed and his father, Nazar Mohamed, and the use of a rarely invoked legal theory to pursue alleged foreign tax fraud.

The authors analyze the implications of the U.S. Supreme Court’s 2005 decision in Pasquantino v. United States, exploring the limits of U.S. jurisdiction over alleged foreign tax offenses.  The authors also discuss other legal challenges the Mohameds may raise, including allegations of vindictive prosecution. Their article examines the complex intersection of international tax enforcement, criminal tax law, and questions of prosecutorial authority.