The Fifth Amendment and Offshore Audits

This course delves into the Fifth Amendment's historical foundations, tracing its evolution from English common law protections against torture and involuntary confessions. By exploring key figures such as John Lilburne and landmark legal documents, we will examine how these early protections shaped the Constitution's approach to self-incrimination. The course will also highlight the broader applications of the Fifth Amendment, with a particular focus on its relevance in offshore tax cases, and provide an in-depth look at the documentary production privilege. Key case law will be reviewed to demonstrate how these protections are applied in tax law today.