Criminal
- Defend the former campaign chairman to the President of the United States in a matter brought by the Office of the Special Counsel concerning tax and Bank Secrecy Act (BSA) violations, conspiracy, money laundering, mortgage fraud and violations of the Foreign Agents Registration Act (FARA).
- Represent the former chief operations officer and member of the board of directors of an international financial institution where the U.S. Department of Justice is investigating allegations of tax evasion, Bank Secrecy Act violations and conspiracy.
- Represent a foreign professional in a pending matter involving allegations of securities fraud and conspiracy in which a “pump and dump” scheme is central to the case.
- Defend a former manager of an international bank with respect to a bank client’s evasion of tax. This matter remains pending, although the bank’s client entered a guilty plea, paid $100 million to the Internal Revenue Service, and was sentenced to seven months in prison.
- Retained by multiple foreign financial institutions to serve as an Independent Examiner pursuant to the U.S. Department of Justice program involving the banks’ cross-border business and the use of undeclared accounts by U.S. persons.
- Represented a foreign asset manager with respect to a criminal tax conspiracy involving undeclared accounts held by U.S. persons. Though the client was charged, the matter was resolved short of trial and the client received no jail time.
- Represented a foreign bank relationship manager with respect to a criminal tax conspiracy involving thousands of undeclared bank accounts held by U.S. persons. The indictment charged that the offshore bank was managing approximately $4 billion in total assets in undeclared accounts at the time. The client received two years of unsupervised probation.
- Successfully defended an attorney in a tax shelter prosecution that charged the client with criminal conspiracy and obstruction. After a four-week trial, the jury acquitted the client on all counts. The charges related to complex sale-leaseback transactions designed by a major accounting firm and engaged in by numerous Fortune 500 corporations. The alleged tax loss was more than $200 million.
- Successfully represented the chief executive officer of an oil trading company in a criminal investigation conducted by the U.S. Attorney’s Office. The investigation focused on LIFO inventory accounting issues relating to the client’s various corporations (which generated between $3 and $4 billion in sales annually). The criminal investigation was closed with no charges being brought.
- Represented the primary target in a criminal investigation where the government alleged that the client established, participated in, and promoted sophisticated tax shelters that resulted in more than $110 million in illegal tax deductions for various corporations. The government closed the criminal investigation with no charges being brought against the client.
Civil
- Represent two clients in a multi-million dollar offshore voluntary disclosure matter against the Internal Revenue Service.
- Represented a global insurance company in a multi-million dollar refund suit in U.S. district court alleging that the government abused its discretion in denying benefits under the relevant tax treaty.
- Defended a lawyer in a civil penalty audit where the IRS initially asserted that the client participated in and promoted listed tax shelters that resulted in more than $100 million in improper tax deductions.
- Represented taxpayers in a U.S. Tax Court case involving corporate expenses claimed on various income tax returns. The IRS claimed additional taxes, penalties and interest of approximately $2 million.