US Tax Investigations

In this ever changing and challenging environment, our US Tax Investigations team will work with you to prevent, efficiently manage, and resolve tax examinations and disputes. We have a highly experienced global team of Partners and Of Counsels, from both our Tax and Litigation practices, who can assist you in virtually every area of dispute. We combine deep technical understanding, local knowledge, strong relationships with government officials, tax litigation experience, and a global perspective to provide our clients timely and thoughtful advice.
 
 
Approach
 
With tax investigations, a one size fits all approach simply does not work. Our team will carefully review your issues and develop a strategy of responses and solutions based on years of procedural and substantive tax experience. Our goal is to resolve a client’s case by balancing the value of an early resolution against the costs and potential outcomes of tax litigation. We counsel, negotiate and, when appropriate, aggressively advocate for our clients in tax investigations and prosecutions.

We represent clients before Examination, Collection and Criminal Investigation divisions of the IRS. We are particularly proud of our ability to negotiate the ethical minefield of representing our clients in Eggshell Examinations, i.e., those examinations involving potentially large tax assessments and civil and/or criminal penalties. 

We represent individuals and entities that have been accused of owing tax or being criminally liable for not complying with tax law. We have defended our clients against a broad range of tax crimes, including, but not limited to: tax evasion; evading/obstructing the collection of tax; negligent/fraudulent tax return preparation; failure to report income; fraudulently overstating deductions; failure to withhold and/or pay over employment tax; and failure to charge and/or remit sales tax.

We pride ourselves on our ability to work with the criminal investigation arms of governmental authorities to avoid indictment of our clients by virtue of our reputation for integrity, our ability to negotiate and, when necessary, to cooperate with ongoing investigations. That being said, we are adept at the art of knowing when not to cooperate. Whether we are brought in at the beginning of a tax controversy or after attempts at resolving the issues have been unsuccessful, we excel at providing cost-efficient and effective advice for our clients.
 
 
Services
 
  • Tax Examinations/Audits
  • Tax Collection Defense
  • Defense against Summons Enforcement
  • Civil and Criminal Tax Litigation (in Federal and State Courts)
  • Voluntary Disclosures (offshore, domestic and state/multistate)
 
 
Our Clients
 
 Our clients include high net worth individuals, large multinational corporations, all business entities, trusts, and estates. We have represented our clients in controversies in most substantive areas of tax, including income, sales, estate and gift, employment and excise taxes. We counsel our clients in all phases of their tax examinations from the initiation of a tax audit/examination, drafting tax protests in order to negotiate with the IRS Office of Appeals and litigation in the U.S. Tax Court. We also have extensive experience in representation at all levels of the state and local tax administrative and court systems.
 
 
Recent Work
 
  •  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 was able to have case returned to a civil examination and resolution.
  • 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 was able to have case returned to a civil examination and resolution.
  • Successfully negotiated multi-state voluntary disclosure involving over 30 states.
  • Defended individual in NYS nonresident tax examination before the Division of Tax Appeals involving assertions of statutory resident status and the reconstruction of client records with supporting testimony and evidence of pattern activity without having to produce the types and volume of documentation typically required.
  • 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 Services civil tax exam with underlying criminal issues. Negotiated a proposed adjustment from $1,000,000 in tax to $10,000 with no criminal penalty. 

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