305-521-0077
Criminal Tax
The IRS is increasing its criminal investigations. Over the last five years, IRS audit and collection activity has decreased dramatically. There has, however, been a sharp increase in criminal investigations. The IRS has officially stated that the agency is broadening and expanding the scope of criminal tax investigations. If you believe that you have been targeted for a potential criminal investigation, call us. We can represent you at all stages of an administrative or grand jury investigation and, if necessary, at trial in U.S. District Court. We are experienced in the following areas:
- Tax return preparer and accountant cases.
- Tax evasion and attempted tax evasion
- False statements to the IRS
- Money laundering
- Structuring of financial transactions
- Asset forfeitures
- Negotiation of plea agreements
- Intentional failure to file tax returns
- Intentional failure to pay
- Abusive trusts, offshore financial arrangements
The IRS initiates thousands of criminal investigations each year, running from failure to file tax returns to more complex tax evasion cases. The penalties associated with a criminal case include imprisonment, heavy fines, loss of voting privileges, loss of professional licenses, restitution orders, and probation. Criminal cases often will turn on decisions made at the beginning of the case and will significantly impact the potential punishment. By the time you are contacted by the IRS Special Agents, it is likely that they have been conducting their investigation for many months. It is important to immediately contact tax counsel so the procedural posture of the investigation can be assessed. Our goal is to work through the IRS and Department of Justice to present legal and factual arguments to avoid or limit potential criminal charges. We provide experienced advice on the most appropriate course of action, which can range from a plea bargain to trial. With a plea bargain, timing is critical. The longer you wait, the less likely you are to receive the most favorable terms.
Sample engagements..... call us if:
- You need to respond to a government summons or subpoena
- You need representation before a grand jury or before a criminal IRS Special Agent
- You need help in presenting legal and accounting issues to Department of Justice or IRS
- You need representation at trial
