Devoted to Corporate Attorneys, Corporate Lawyers, and Corporate Counsel

The following is not meant to be legal advice.

The DOJ policy comes after a recent decision in United States v. Stein, 435 F. Supp. 2d 330 (S.D.N.Y. 2006), also known as the KPMG tax shelter case.  The case held that the DOJ’s then-existing guidelines for the prosecution of business organizations, (set forth in the so-called "Thompson Memorandum") were unconstitutional.