Seth G. Cohen

Partner

  • Education: CUNY at Hunter College, cum laude, B.S. • Boston University, J.D.
  • Admitted: State of MA, 1998 • State of CT, 2003 • United States Tax Court, 2004 • State of NY, 2005 • Registered Foreign Lawyer in the UK, 2013 • US District Court, District of Connecticut , 2015
  • Year joined: 2014
  • Year became partner: 2014

Overview

Seth G. Cohen advises and represents individuals and entities worldwide in:

  • Voluntary Disclosures
  • Sensitive civil tax examinations/audits
  • Criminal tax and fraud investigations
  • U.S. investigations of financial professionals and institutions, other entities and advisors on criminal tax issues
  • Actively represents art purchasers, galleries and auction houses in tax related government investigations and audits, involving: the New York State Attorney General's office; the New York State Department of Taxation and Finance; the United States Department of Justice; and the Internal Revenue Service.

Summary/Highlights

Seth is an experienced tax compliance litigator who represents clients in U.S. federal, state and local controversies. He has extensive experience in counseling individuals, entities and financial institutions in relation to the U.S. government's focus on undeclared foreign accounts. Currently, he is representing numerous clients worldwide in United State Department of Justice, Internal Revenue Service and state attorneys general in audits/examinations/investigations that have arisen in the normal course, through whistleblowers, and the recent U.S. focus on undeclared offshore accounts. He travels to Asia extensively to service clients and speak on subjects within his areas of expertise. He is an adjunct professor of tax and law at the University of New Haven in Connecticut.

Highlights

  • Persuaded IRS and Connecticut not to criminally prosecute individual who failed to file individual, withholding, sales and corporate tax returns for 8 years as a result of emotional turmoil and the general economic downturn.
  • Negotiated with IRS for a decrease in the civil miscellaneous penalty associated with the Offshore Voluntary Disclosure Program as a result of partial compliance.
  • Represented client in examination emanating from IRS Criminal Investigations and through negotiation were able to have case returned to a civil examination and resolution.
  • Represented TEFRA Partnership in IRS examination that was settled at the IRS Office of Appeals and reduced a proposed deficiency from $12 Million to nothing.
  • Represented restaurant chain in case originating in the Criminal Enforcement Unit of New York State and negotiated a civil resolution.
  • Successfully negotiated multi-state voluntary disclosure involving over 30 states.
  • Reconstructed books and records to determine civil tax liabilities to successfully avoid referral to a criminal tax enforcement authority where significant criminal exposure existed.
  • Successfully defended individual in Connecticut charged with criminal contempt in significant failure to remit sales/withholding tax case avoiding substantial incarceration sentence.
  • Represented corporation in Connecticut Department of Revenue civil tax exam with underlying criminal issues. Negotiated a proposed adjustment from $1,000,000 in tax to $10,000.

Publications and speaking engagements

  • Quoted, "For Caterpillar, Federal Raid May Mean More Than Tax Trouble," Law360, March 30, 2017.
  • Co-author, "New Partnership Audit Rules Require Major Decisions," Accounting Today, March 10, 2017.
  • Moderator, "Gift Tax Returns & IRS Examination: Challenges and Pitfall of Practitioners," New England IRS Representation Conference 2016, November 2016.
  • Co-Author, "New York Sales Tax Settlement Could Change The Way Art World(And Others) Do Business," Forbes, August 9, 2016.
  • Quoted, "Uncle Sam Widens Hunt for Tax Cheats in Asia," Barron's Asia, July 6, 2016.
  • Panelist, "Trends and Pitfalls in the Age of tax Transparency," Hong Kong, May 2016.
  • Co-Author, "How Art Collectors Can Stay Out of Tax Trouble in New York," Forbes, May 10, 2016.
  • Presenter, "Singapore in the Spotlight &ndash The US Campaign against Undeclared Offshore Accounts" J. Safra Sarasin Trust Company, Singapore, May 2016.
  • Presenter, "In the Cross Hairs of the IRS Global High Wealthy Industry: 2016 Triggers and What You Can Do," 2016 Family Office Association Global Summit, Greenwich, CT, April 2016.
  • Panelist, "Dealing With a Decedent's Tax Fraud: Cleaning Up Our Dead Client's Bad Behavior," ABA Tax Section 2016 Midyear Meeting, Los Angeles, CA, January 2016.
  • Presenter, "Trends and Opportunities in Citizenship Planning," HSBC Private Bank, Singapore, October 2015.
  • Presenter, "Foreign Account Tax Compliance Act (FOR1)," Surgent Professional Education webinar, June 2015.
  • Panelist, "Litigation and Arbitration - A global perspective," Withersworldwide Seminar, Singapore, April 2015.
  • Panelist, "Tax Controversy: Handling Audits, Appeals, Litigation, and Collections for Clients LIVE Webcast," The Knowledge Group, February 2015.
  • Speaker, "Understanding IRS Criminal Tax Issues," The Brooklyn Bar Association, Brooklyn, NY, June 2014.
  • Speaker, "The Eggshell Audit: Identifying and Handling Cracks in Client Returns," New York, New Haven, Greenwich, June 2014.

Memberships

  • American Bar Association, Administrative Practice Committee and Civil and Criminal Tax Penalties Committee
  • American Institute of Certified Public Accountants, Non-CPA Faculty Member
  • Connecticut Bar Association
  • New York City Bar Association

On a personal note

Seth enjoys spending time with his wife Geraldine, his two sons and two dogs. He is also an avid music fan particularly in the opera, classical and progressive rock genres.

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