Criminal Tax Fraud Investigations & Penalties

Kostelanetz has built a national and international reputation as one of the country’s preeminent law firms engaged in defending individual and corporate clients against criminal tax fraud investigations and prosecutions. 

Our nearly 80-year history of focusing on tax controversies and white-collar criminal defense is the cornerstone of our success. We have more tax fraud and tax controversy attorneys than most large firm practice groups. Large firms often call on our attorneys as co-counsel in some of the most challenging, complex, and sensitive tax controversy cases because there are very few issues or fact patterns that we have not encountered in our experience with alleged tax evasion, tax fraud, and other tax-related criminal cases. In short, our firm has the talent and resources to respond to any challenge from both federal and state tax authorities. 

With our attorneys’ in-depth knowledge of tax law and our extensive courtroom litigation experience, we craft defense strategies tailored to our clients’ specific situations, and our attorneys are tenacious advocates for our clients every step of the way. We are skilled in negotiation with law enforcement authorities such as the Justice Department, the Internal Revenue Service (IRS), international tax administrations, and state revenue agencies. Our successes include acquittals at trial, persuading prosecutors to abandon criminal investigations, agreements for deferred prosecution, reduced penalties, and, if conviction is inevitable, favorable sentencing outcomes.

We have represented thousands of taxpayers, including corporations and individuals nationwide and outside the United States in cases involving the following:

• tax shelter promotors,
• allegations of failure to report income, 
• overstated deductions, 
• failure to collect and pay employment taxes, 
• preparation of false tax returns, 
• failure to file returns, 
• presentation of false documents to the IRS, 
• conspiracy to impede or obstruct the IRS, 
• the failure to report foreign assets and bank accounts, and
• other tax-related crimes, such as structuring and currency transaction reporting violations.

Our firm’s extensive tax experience serves us well in representing clients faced with criminal tax fraud investigations conducted by the IRS, the Department of Justice Tax Division, local United States Attorneys’ Offices, or state prosecutors, as well as cross-border investigations involving both U.S. and foreign law enforcement agencies. Approximately half of the firm’s tax fraud team has significant government experience, including a former Acting Assistant Attorney General of the Department of Justice (DOJ) Tax Division, a former Chief of the IRS Criminal Investigation, several attorneys with experience in the IRS Office of Chief Counsel, a former Special Trial Attorney for the IRS Office of Chief Counsel in New York, several attorneys with criminal and civil DOJ Tax Division experience, and several former Assistant United States Attorneys.