Tax investigations and controversy lawyers
Our international tax investigation team is made up of highly experienced professionals in the UK, US and Asia who have spent decades advising on complex and high-stakes cases.Having acted in many high-profile cases, we know that a 'one-size-fits-all' approach does not work, and we will carefully review your situation and develop a tailored strategy.
We can all agree that tax is now a more contentious issue than ever before, with the press naming and shaming accused tax avoiders as well as evaders and government giving treasury and regulators greater powers to investigate, penalize and prosecute individuals and businesses. We are frequently consulted by people who have inadvertently signed up to a tax 'scheme' of some kind and are currently representing individuals and companies caught up in film schemes as well as high profile individuals in the work of international football.
We also help those who wish to make a voluntary disclosure of unpaid taxes, ensuring that the process is handled confidentially and with protection from criminal investigation wherever possible.
In the UK, we offer robust advice on civil and criminal tax fraud investigations and litigation by the tax authorities. Our team includes lawyers who have worked within the tax authorities and have valuable insight into their methods and approach.
Any controversy related to tax can be damaging, regardless of whether there has been any wrongdoing. It is for this reason we offer the services of our reputation management team, who can help to manage coverage of cases where there is a media interest.
London banker facing bankruptcy proceedings
We acted for an investment banker in London who was facing bankruptcy proceedings as a result of a petition from HMRC for non-payment of tax. The non-payment was related to the sale of bank shares where she previously worked, which would have had a significant impact on her livelihood. We negotiated with HMRC on her behalf, saving her from bankruptcy proceedings and without adverse publicity.
We frequently advise UK residents who are non-domiciled, where they are under investigation by HMRC. This can the take the form of inquiries into their residence as well as their claim to be no-domiciled and also where challenged are made into specific remittances. It is a complex area, where we work closely with our wealth planning colleagues. We have had several notable success in this area in the past few years.
Senior professional involved in tax fraud
Our team in London is advising a senior professional in relation to tax fraud, taking him through a Contractual Disclosure Facility ("CDF"). This type of voluntary disclosure that allows individuals to own up to tax fraud, in return for a promise from HMRC not to commence a criminal investigation. He was extremely concerned about the process and subsequent investigation, but our team helped to simply and speed up the process, managing communications with HMRC and allowing the client to move on with his life.
Negotiating voluntary disclosures
Assisting clients in negotiating disclosures under the Liechtenstein Disclosure Facility (LDF) for clients with complex offshore structures - sometimes working in tandem with US qualified colleagues when the client also needed to make a voluntary disclosure in the US.
Tessa Lorimer, a member of our tax investigation team in London, advised on a £5 million pension fraud involving accountants who were acting as trustees and administrators of Pension schemes which were investigated by HMRC, FSA and the Pension Regulator.
Colombian family IRS case
We represented a Colombian family with interests in Colombia and Brazil, which had been briefly stationed in the United States, with a delicate IRS matter. We assisted the family in negotiating a penalty abatement of upwards of US$1.6 million in potential penalties, and all of the IRS meetings and negotiations were addressed without clients needing to be physically present in the United States.
US tax compliance for Brazilian entrepreneur
We investigated the circumstances of a client who was a Brazilian entrepreneur investing in the United States. We determined that he had inherited United States citizenship from his parents but had never filed US income tax returns or reporting forms. We quickly and efficiently addressed the noncompliance by entering him into the IRS offshore streamlined program.
Canadian and Swiss accounts tax case
We successfully abated over USD $2.8 million in potential penalties for a Canadian family living in America, advising on an IRS defense action with respect to Canadian and Swiss accounts.
Managing Canadian-US reporting obligations
A Canadian-US family living on both sides of the US-Canadian border asked us to assist with US reporting deficiencies (FBAR, FATCA, income tax returns, entity reporting, etc), where the potential IRS penalties well exceeded USD $1 million. We successfully negotiated full penalty waiver on all missed reporting forms for all impacted family members.
A US citizen who had not filed tax returns
Our New Haven office persuaded the IRS and the state of Connecticut not to criminally prosecute a client who had failed to file individual, withholding, sales and corporate tax returns for eight years as a result of the economic downturn and some personal emotional turmoil.
High-profile individuals in football
We are acting for a number of figures in the international football industry in relation to a Code of Practice 8 (COP 8) investigation. Our clients were missold investment schemes that amounted to tax avoidance, and we are dealing with HMRC on their behalf and negotiating a settlement with their negligent advisers.
The UK's non-dom regime – time to reform rather than replace?
Changes to the UK's non-dom regime are considered to be inevitable. Read our report to find which changes we suggest, and how well the regime is currently functioning for non-doms.
The UK "non-dom" regime
"Non-doms" have returned to the political spotlight.
In our series of articles we explore what the UK "non-dom" regime is, what it may look like in the future as a result of potential political change and the alternatives regimes available across the world.
Read our short articles below to find out more.
2 November 2023 | Article
Offshore non-compliance and HMRC's Worldwide Disclosure Facility – Traps for the unwary
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