BakerHostetler’s Criminal Tax Defense team operates at the confluence of white-collar criminal litigation and tax law. We combine our knowledge of criminal law and procedure with our technical tax expertise to represent businesses and individuals who are under investigation or indictment for tax offenses. We also conduct discreet internal investigations for businesses that suspect wrongdoing by their officers or other employees. Our extensive government and private sector experience helps our clients achieve favorable negotiated resolutions and, when appropriate, to put the government to the test at trial.
We have particular expertise in defending holders of foreign bank accounts in IRS “offshore audits” and offshore criminal investigations and prosecutions. With foreign banks turning over vast amounts of information on their American customers, the U.S. government is aggressively pursuing those who have failed to disclose their accounts.
Our team is led by attorneys who have extensive experience in the criminal tax arena and includes several former assistant United States Attorneys, a former assistant chief of the Department of Justice Tax Division Criminal Enforcement Section, and a former Internal Revenue Service (IRS) Office of the Chief Counsel attorney.
Our lawyers have successfully represented clients at each stage of the criminal tax process, from IRS administrative investigations conducted by special agents from IRS Criminal Investigation to joint IRS-Department of Justice grand jury investigations to indictments and prosecutions by U.S. Attorney’s offices. Regardless of the stage of the proceedings, however, our goal throughout is to minimize the impact on our clients of being the target of the government’s substantial investigative and prosecutorial resources.