Civil Lawsuits
Served as lead counsel and obtained multi-million-dollar recovery for multiple clients in lawsuits against multinational Fortune 50 company.
Tax Litigation; Wrongful Seizure
Provided tax advice to a Dallas-based family office in the recapitalization of a limited partnership formed to acquire royalty and mineral interests. The engagement involved soliciting existing members for additional capital contributions and the repurchase of limited partnership interests from partners wishing to liquidate their investment, as well as the negotiation of a new $7 MM loan consisting of a $3 MM term loan and a $4 MM line of credit.
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.
Civil Lawsuit
Won lawsuit involving shareholder dispute and claims of embezzlement involving seven-figure damages.
Civil Litigation
Represented company and recovered hundreds of thousands of dollars on behalf of client from former embezzlement.
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 Government Litigation
Represented clients in litigation with Department of Justice regarding Federal Communications Commission (“FCC”) monetary penalty; obtained removal of judgment against individual client and 97% reduction of penalty for remaining clients.
Tax Planning
Drafted Private Letter Ruling to obtain IRS consent to tax treatment.
Tax Litigation; U.S. Virgin Islands
Represented client in Tax Court litigation, challenging IRS proposed assessment denying United States Virgin Islands (USVI) bona fide resident status and tax benefits; obtained concession from IRS and full tax benefits.
Other Representative Cases
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; Parallel Proceedings
Represented client in multiple, parallel federal proceedings, including federal criminal proceedings and indictment for bankruptcy fraud and money laundering; SEC securities fraud proceedings; and federal civil action for alleged $200 million fraud. Obtained dismissal from federal suit alleging $200 million damages and release of client from prison.
IRS High-Wealth Audits; Puerto Rico
Represented client in IRS “wealth squad” (Global High Wealth Industry Group) audit involving Puerto Rico Act 20/22 benefits; obtained “no-change” audit.
IRS Tax Representation; Puerto Rico
Represented client in challenging IRS assessment denying Puerto Rico Act 20/22 benefits; obtained reversal and removal of full assessment.
Tax Litigation
Represented clients in proceedings to quash international tax Formal Document Requests, seeking documentation regarding foreign accounts.
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.
White-Collar Criminal Defense; Non-Prosecution
Represented client in grand jury investigation with respect to allegations of perjury, obstruction of justice, and financial kickback scheme, obtaining United States Attorneys Office’s agreement not to prosecute.
White-Collar Criminal Defense
Represented client accused of bank fraud involving in excess of $50 million.
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.
Government Penalty Representations
Obtained complete removal of substantial Affordable Care Act (“ACA”) Employer mandate penalties.
State Tax Litigation
Represented company as lead counsel in Texas state franchise tax dispute involving assessments of more than $1.5 million and assertion of Texas sourcing based on location of computer servers and electronic storage. Obtained complete removal of franchise tax assessment.
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 Tax Penalty Representation
Obtained penalty abatement and removal of IRS penalties in excess of $14 million.
Federal Tax Litigation
Represented client in Tax Court, obtaining complete removal of more than $300,000 in tax assessments.
Innocent Spouse Relief/Penalty Relief
Obtained innocent spouse relief, removing liability for tax liabilities of more than $500,000.
Innocent Spouse Relief/Penalty Relief
Obtained innocent spouse relief, removing liability for tax liabilities of more than $600,000.
Innocent Spouse Relief/Penalty Relief
Obtained innocent spouse relief, removing liability for tax liabilities of more than $1,000,000.
Appellate
Served as appellate counsel in Fifth Court of Appeals in case involving allegations of fraud among business owners. Obtained appellate victory.
Transactional
Represented clients in international corporate reorganization, involving liquidation of foreign subsidiary and FIRPTA planning.
Transactional
Represented client involving restructuring of international fund and corporate structure, as well as corporate dissolution.
IRS
Represent client in IRS offer in compromise involving offer to compromise tax debt of more than $15 million for less than $100,000.
IRS
Represented client in obtaining IRS offer in compromise, settling tax debt of more than $1 million dollars for less than $150,000.
Transactional/Cryptocurrency
Represented client in international corporate structuring and blockchain-based cryptocurrency token development.
IRS Trust Fund Recovery Penalty
Represented client against IRS assessment of Trust Fund Recovery Penalty. Obtained complete removal of Trust Fund Recovery Penalty.
Cryptocurrency Tax
Represented client with significant cryptocurrency transactions, reducing reported taxable transactions from cryptocurrency events by more than $1 million.
Tax Opinions
Tax planning and opinion regarding capital gains treatment in complex transaction, resulting in tax savings.
International Tax
Advised Hong Kong entity regarding reorganization and federal tax compliance obligations and planning.
International Transactional
Served as counsel and advised client regarding multi-million-dollar international asset purchase agreement.
International Transactional
Served as counsel and advised client regarding multi-national corporate manufacturing and business structure, including guiding client with respect to international tax compliance.
