Supreme Court Interprets Tax Offenses and Aggravated Felonies

Late last month, the Supreme Court of the United States decided Kawashima vs. Holder. In an important decision outlining the boundaries of what constitutes an aggravated felony, the Court held convictions under 26 USC §§ 7206 (1) and (2) in which the government's loss exceeds $10,000 do qualify as aggravated felonies under 8 U.S.C. § 1101(a)(43)(M)(i). The two aforementioned statutes are tax crimes which the Court held are not solely limited to clause (ii) of 8 U.S.C. § 1101(a)(43)(M), which covers an offense "described in section 7201 of title 26...in which the revenue loss to the Government exceeds $10,000."