When you receive a subpoena or government notification of a potential criminal investigation, you can turn to us to defend your interests fiercely and effectively. Our team includes practitioners who are top-ranked in both criminal and tax matters, combining a wealth of white collar defense experience with a deep understanding of criminal tax procedure and the tax code.
In complex criminal tax cases, you need a legal team with the skill to navigate tax nuances and build a solid tax defense within the framework of criminal law—from discovery rules to Rule 16 of the Federal Rules of Criminal Procedure and beyond. We use our experience with criminal tax procedure and credibility with our strong government connections to help you achieve the most favorable outcome. Whether you are an individual or multinational company, or anything in between, we can represent you in sensitive audits, subpoena responses, search warrants, voluntary disclosures, investigations, plea negotiations, trials, sentencings and appeals.
We also draw on our experience advising clients in developing and strengthening compliance programs and conducting internal investigations, which are critical to your success as criminal tax enforcement continues to reach domestic and international business entities such as financial institutions and accounting firms.
To help you anticipate potential issues and stay ahead of the curve, we proactively advise on upcoming challenges, new legislation and areas of IRS enforcement, and emerging trends such as cryptocurrency. When you do face a criminal investigation, we have a proven record of obtaining dismissals or settlements—and when taking your case to court is the only option, our reputation as fearless, capable litigators precedes us. Our team members have collectively handled more than 120 criminal tax investigations and more than a dozen criminal tax jury trials, and our ability to speak to courts, judges and juries clearly and effectively in defending criminal tax cases is well-known and respected.
You also benefit from our extensive, current knowledge of the US Department of Justice (DOJ)’s organization, rules, practices and people. Leveraging the experience a former trial lawyer from the DOJ, Tax Division, Criminal Enforcement Section, along with lawyers who have joined us from US Attorney’s Offices across the country, we are among the best criminal tax teams in the US.
Achieved a declination of charges in multiple criminal tax investigations
Prepared Supreme Court brief on behalf of the American College of Tax Counsel in support of the successful petitioner in Marinello v. United States
Convinced Court of Appeals to reverse district court’s order denying motion for return of $12 million seized by IRS in criminal tax investigation
Defended employees of international bank in connection with a Department of Justice money laundering and tax evasion investigation
Represented large accounting firm and several investors in the tax shelter prosecutions brought in the Southern District of New York
Guided numerous individuals through successful voluntary disclosures
Representing a large accounting firm in multiple conservation easement investigations conducted by the Department of Justice Tax Division
Represented the owner of a South American cattle transportation business in criminal tax and money laundering investigation by the US Attorney’s Office in the SD of Florida securing a declination of all charges
Represented a large accounting firm in numerous grand jury investigations, including the prosecution of a former partner
Represented accounting firms in numerous SEC investigations
A diverse, global network of industry-leading talent committed to you and your vision.