Criminal Tax Defense

Attorneys in Freeman’s tax controversy and litigation practice have been named to U.S. News and World Report’s Best Lawyers in America list, recognized by Chambers & Partners as among the leading tax and litigation attorneys in the United States, including for fraud representations, and recognized as the “Leading Tax Controversy Litigation Attorney of the Year” for the State of Texas.
Our tax litigation attorneys include former IRS trial attorneys, former clerks to the Chief Judge of the United States Tax Court, tax law professors, dual-credentialed CPAs, and attorneys with advanced LL.M. tax degrees from the most prestigious tax programs in the nation. One third of our attorneys a law professors at tier one law schools, teaching tax law.
We regularly take on the nation’s biggest litigation firm: The Department of Justice. We bring a systematic approach to investigations, tax defense, and trial; and rewriting the odds in complex, criminal tax matters, one case at a time.

Criminal Tax Defense

Freeman has a national reputation as a “go-to” criminal tax defense firm. We vindicate, mitigate, and defend our clients against government allegations, bringing big-firm talent, think-tank intellect, and strategic insight to their corners. We are hyper focused; responsive; and battle-tested. And we are rewriting the odds in complex, criminal tax matters one case at a time.

We combine unique white-collar criminal defense experience with substantive tax knowledge. Our attorneys are client-focused problem solvers. They are steeped in substantive tax expertise gained from years of experience in the trenches and provide sophisticated representation and penetrating legal acumen.

Best Lawyers® and U.S. News & World Report have recognized Freeman as a “Tier 1” Tax Law firm and our tax attorneys have garnered national recognition for their tax defense work, such as:

The “Leading Tax Controversy Litigation Attorney of the Year” for the State of Texas
U.S. News – Best Lawyers® Best Lawyers in America
The Best Lawyers in America®, Chambers USA

In criminal tax matters, the right move at the right time can mean the difference between the right outcome and the wrong one. We begin thinking through the end game from day one. We sift through and evaluate the case, cultivating its thematic essence and distilling complex facts into clear and compelling narratives and defenses. From day one, we evaluate a game plan to “kill” the case. Many of our most successful representations never see the light of day.

Criminal tax matters may turn upon a taxpayer’s or professional’s state of mind as well as the most detailed, nuanced accounting and finance calculations and concepts. We often conduct our own investigation, analyzing applicable defenses and addressing ongoing IRS investigations.

Our firm and attorneys maintain a reputation for integrity and vigorous representations defending criminal tax prosecutions and investigations, often seeking to convince government decision-makers to decline prosecution.

Consistent with national recognition of our tax practice, Freeman hosts the world’s largest international tax conference, focusing heavily on civil and criminal tax litigation developments in the United States and internationally.

Our criminal tax representations include, among others, matters involving:

Tax evasion
Offshore trusts and foundations
Offshore accounts
Accounting irregularities
Off-balance-sheet
Unreported income
Over-reported expenses
Over-reported expenses
Conservation easements
Tax shelters

Our attorneys have experience defending against a range of government agencies, with a particular focus on the IRS. Well-versed in high-stakes criminal tax defense, our attorneys are trial-ready and battle tested; we’re ready when you are.

Representative Matters

Criminal Tax:

Represented attorney in federal indictment for tax evasion.
Criminal Tax:

Represent client in alleged $12 million tax evasion.
Criminal Tax Investigation; Non-Prosecution:

Represented client in criminal tax investigation by IRS Criminal Investigation Division involving allegations of income tax evasion; “killed investigation,” obtaining agreement from IRS CID not to seek prosecution against client.
Criminal Tax Investigation; Non-Prosecution:

Represented client in criminal tax referral involving allegations of income tax evasion; “killed case,” obtaining declination to prosecute client from United States Attorneys Office.
Criminal Tax Investigation; Non-Prosecution:

Represented client in criminal tax investigation by IRS Criminal Investigation Division involving allegations of income tax evasion; “killed investigation,” obtaining agreement from IRS CID not to seek prosecution against client.
Criminal Investigation; Seizure; Non-Prosecution:

Represented client under federal investigation for laundering and facilitating cryptocurrency exchanges following government seizure of cash. “Killed case,” and obtained government declination to pursue criminal charges, as well as obtained return of all seized funds.
State Criminal Tax Investigation; Non-Prosecution:

Represented client in state criminal tax investigation and obtained dismissal of charges.
Criminal Tax Investigation; Non-Prosecution:

Represented client in federal criminal investigation related to alleged healthcare fraud and false statements, and obtained non-prosecution.
White-Collar Criminal Defense:

Lead criminal defense counsel for client indicted for allegedly hacking Microsoft and EA Sports company servers and illegally obtaining more than $20 million of virtual currency laundered through Russian and Chinese secondary markets. Obtained resolution of no prison time for client.
White-Collar Criminal Defense:

Represented client in federal criminal charges involving alleged mail and wire fraud, money laundering, and false statements related to Federal Election Code and political action committees.
Criminal Tax Defense:

Represented client as criminal counsel in federal criminal case in United States Virgin Islands involving allegations of criminal tax evasion and conspiracy.
Appellate:

Served as lead appellate counsel in federal court of appeals (Third Circuit Court of Appeals, St. Croix, USVI), providing oral argument in federal tax case.
Federal Criminal Defense:

Following appointment as counsel, initiated investigation and obtained release of client from prison after uncovering wrongful investigative actions and entrapment.
IRS “SEP” Audit/Investigations:

Represented client in Special Enforcement Program (“SEP”) audit/investigation involving millions of dollars of alleged unreported income and several million dollars of unpaid tax and assessments; obtained deal to avoid criminal referral and avoidance of fraud penalties.
IRS International Penalty Defense and Voluntary Disclosure:

Represented client in IRS offshore voluntary disclosure, guiding client through an “opt out” and reducing penalties by hundreds of thousands of dollars through penalty defense.
Criminal Tax Defense:

Represented client against criminal tax evasion charges involving allegations of the evasion of tax in excess of $1.5 million. Obtained result of no prison time.
IRS Voluntary Disclosure/Cryptocurrency:

Represent client in IRS voluntary disclosure involving multi-million-dollar cryptocurrency holdings.

Criminal Tax Defense