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Courses/Law/Evidence

From Summonses to International Evidence Gathering Technique

International Tax Compliance and IRS Evidence-Gathering: Balancing Enforcement with Taxpayer Rights

Created byMichael J. DeBlis III, Esq.
BeginnerUpdated Sep 17, 2025
From Summonses to International Evidence Gathering Technique

What You'll Learn

check_circleCompare dual-purpose summonses with traditional IRS summonses and analyze the implications for taxpayer privacy.
check_circleExamine the challenges the IRS faces when using grand jury subpoenas versus administrative summonses, focusing on compliance and enforcement issues.
check_circleUnderstand how international business practices have shaped the IRS's evidence-gathering techniques, particularly in addressing tax fraud.
check_circleEvaluate the impact of the Foreign Account Tax Compliance Act (FATCA) on the relationship between U.S. taxpayers and foreign financial institutions regarding information disclosure.
check_circleAnalyze the ethical dilemmas foreign financial institutions encounter when complying with U.S. tax laws in jurisdictions with strict bank secrecy regulations.
check_circleAssess the effectiveness and limitations of Mutual Legal Assistance Treaties (MLATs) in promoting international cooperation for tax enforcement.

About This Course

This presentation will teach you how the government gathers information both domestically and internationally in the 21st century. There are tried and true methods that have been around since time immemorial, as well as new techniques such as FATCA.

We will begin on the domestic side with IRS summonses, subpoenas, search warrants, and sting operations, and then make our way to international evidence gathering.

Specifically, we will discuss mutual legal assistance treaties, tax treaties, information exchange agreements, FATCA, and letters rogatory.

Key Learning Outcomes:

  • Understand the legal basis and procedures for IRS summonses and their enforcement.
  • Identify the requirements and challenges of different IRS investigative tools like search warrants and grand jury subpoenas.
  • Master the complexities of international evidence gathering, including treaties and FATCA.
  • Recognize FATCA reporting mechanisms (IGAs) and their implications for financial institutions and taxpayers.
  • Gain awareness of FBAR requirements and associated penalties.

This course is crucial for legal and financial professionals seeking to understand and navigate the IRS's investigative landscape in an increasingly globalized world.

Your Instructor

Michael J. DeBlis III, Esq.
Michael J. DeBlis III, Esq.

Trial, entertainment law and U.S. international tax law

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star747 reviews

Michael is a partner in the boutique law firm of DeBlis Law where he specializes in tax compliance and entertainment law. Michael graduated from Western Michigan University School of Law in 2007 and later went on to earn his Masters of Law in taxation (LL.M.) from Thomas Jefferson School of Law in 2012. As a former public defender, Michael has spent nearly eight years cutting his teeth on some of the most serious felony cases to pass through the state courts of New Jersey. Michael’s unique background in tax law puts him into an elite category of criminal defense attorneys who specialize in criminal tax defense. His extensive trial experience and solid grounding in all major areas of federal taxation make him uniquely qualified to handle any white-collar case, no matter how sophisticated it might be. Michael is known for his creativity, his charismatic personality, and his unyielding dedication to his clients. As a graduate of the National Criminal Defense College, Michael has trained under some of the best known criminal defense attorneys in the country. That experience has taught him that justice for a person accused of a crime is only won through a full understanding of the client and the case. To that end, Michael attempts to understand each client’s case as a convincing narrative, not just as a set of innocuous facts and arcane legal rules. When he's not in the courtroom, you can find Michael on stage. As a professionally trained actor, Michael's passionate about helping trial lawyers harness the power of persuasion and positive communication in the courtroom in order to connect to the jury on a human level. Michael's training as an actor allows him to combine a unique blend of left-brain thinking with right brain artistry to make even the most dull and abstract areas of the law come to life. This burst of creativity has contributed to Michael's success as a distinguished author and sought-out speaker. Michael has written articles that have been published in leading tax journals, such as "CCH Journal of Tax Practice and Procedure," "EA Journal," "Global Tax Weekly," and "ABA News Quarterly" and is a columnist for "Law360." He has been featured on the media affiliates of several major media networks, including NBC, ABC, CBS, Fox, and CNN. Michael is a living example of the tremendous power that comes from combining passion, preparation, persuasion, and positive communication in the courtroom. His courage and relentless work ethic have earned him a reputation as a zealous advocate and one of New Jersey's rising stars of the legal profession.

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Frequently Asked Questions

We are a registered provider with 327+ associations and regulatory bodies worldwide. We operate across 29 global markets including Canada, the US, Australia, and the UK. Every course page clearly displays its specific accreditations. Upon completion, you receive a professional certificate that can be validated online. Our certificates include all necessary accreditation details, credit hours, and completion dates, and are formatted specifically to meet the submission requirements of most global regulatory bodies.

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