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The IRS's March 25, 2014 declaration that bitcoins are property, not currency, is the final piece of the carefully-crafted Federal approach to bitcoin regulation which greatly differs from the approach of other sovereign nations.
On March 25, 2014, the IRS issued Notice 2014-21, its guidance on the tax consequences of bitcoin dealings. The Notice is the last shoe to drop regarding the federal approach to bitcoin regulation following new guidance from the Financial Crimes Enforcement Network of the Treasury Department (FinCEN) and a round of bitcoin prosecutions by the Justice Department.
The DOJ's Criminal Division issued three declinations since the issuance of the revised CEP a year ago. Review of these cases gives insight into DOJ's implementation of the new policy in practice.
This article discusses the practical and policy reasons for the use of DPAs and NPAs in white-collar criminal investigations, and considers the NDAA's new reporting provision and its relationship with other efforts to enhance transparency in DOJ decision-making.
The parameters set forth in the DOJ's memorandum have implications not only for the government's evaluation of compliance programs in the context of criminal charging decisions, but also for how defense counsel structure their conference-room advocacy seeking declinations or lesser sanctions in both criminal and civil investigations.
Each stage of an attorney's career offers opportunities for a curriculum that addresses both the individual's and the firm's need to drive success.
A defendant in a patent infringement suit may, during discovery and prior to a <i>Markman</i> hearing, compel the plaintiff to produce claim charts, claim constructions, and element-by-element infringement analyses.