We have vast experience handling criminal tax investigations conducted by IRS Criminal Investigation (“IRS CI”), the U.S. Department of Justice Tax Division, and U.S. Attorney’s Offices in Florida and around the nation. Two of our founding partners began their careers as Trial Attorneys with the Department of Justice Tax Division litigating criminal and civil tax cases in federal courts across the country.
Our extensive tax experience serves our clients well when they face criminal tax investigations, often which involve complex tax theories and defenses. In private practice and formerly as government lawyers, we have been involved in sensitive and high-profile criminal tax investigations including investigations into foreign bank account compliance, allegations of money laundering and offshore tax evasion, personal and corporate tax evasion, and alleged fraudulent tax shelters.
We have handled cases involving recent areas of aggressive scrutiny from the government, including Employee Retention Credit (“ERC”) matters, cryptocurrency, microcaptives, syndicated conservation easements, Malta Pension Plans, Puerto Rico Act 20/22/60 issues, prosecutions stemming from the DOJ Tax Division’s Swiss Bank Program, and DOJ’s Panama Papers investigation.
FMH represents individuals and businesses in criminal tax investigations in the Middle District of Florida and other federal districts across the country. If you find yourself the subject or target of an IRS CI administrative investigation or a federal grand jury investigation into allegations of tax fraud or evasion or are considering an offshore or domestic voluntary disclosure, we can help.