Texas IRS Criminal Investigation Lawyer Experienced in High-Stakes Corporate Matters
The federal government has been prioritizing corporate tax compliance in recent years. Not only is the Internal Revenue Service (IRS) targeting corporations with rigorous audits, but IRS Criminal Investigation (IRS CI) is also targeting corporations—and their owners and executives—in tax fraud and tax evasion investigations. As these investigations present risks beyond liability for back taxes, interest and penalties, an informed and strategic defense is essential. Building an effective defense starts with engaging an experienced Texas IRS criminal investigation lawyer as soon as possible.
At Brown, P.C., our lawyers represent corporations in all federal criminal tax matters. While we have extensive experience helping corporations—and their owners and executives—avoid criminal charges, we also provide representation for U.S. Department of Justice (DOJ) prosecutions when necessary. We handle cases involving non-tax-related allegations as well, including allegations of accounting fraud, securities fraud, healthcare fraud, corruption and other federal crimes.
Common Criminal Allegations Against Corporate Taxpayers
Corporate entities can face scrutiny from IRS CI or the DOJ in a wide range of circumstances. In some cases, criminal investigations flow from IRS audits. If revenue agents find reason to believe that a corporation or its personnel have willfully violated the Internal Revenue Code (or any other federal statute), they may refer the matter to IRS CI for further investigation. IRS CI and the DOJ also frequently work with other federal law enforcement agencies, including the U.S. Securities and Exchange Commission (SEC), the U.S. Department of Health and Human Services (HHS), and the Federal Bureau of Investigation (FBI). Whistleblower complaints can trigger criminal investigations as well, and the IRS’s whistleblower program rewards individuals who come forward.
These triggers, among others, can lead to an extremely wide range of criminal allegations against corporations and their personnel. For example, at Brown, P.C., we regularly defend corporate organizations, owners, executives and other clients that are facing allegations of:
Corporate Income Tax Evasion and Fraud
IRS CI and the DOJ are targeting corporations for all forms of income tax evasion and tax fraud. These crimes carry substantial fines for corporate entities, and corporate owners and executives can face both fines and prison time. We handle investigations and prosecutions involving all types of alleged corporate income tax evasion and tax fraud, including (but not limited to):
- Failing to Report Taxable Income
- Underreporting Taxable Income
- Claiming Fraudulent Business Deductions
- Claiming Fraudulent Credits or Exemptions
- Leveraging Abusive Tax Shelters
To substantiate criminal tax evasion or tax fraud investigations, investigators and prosecutors must be able to demonstrate that a corporate entity or individual “willfully” attempted to evade or defeat tax. While challenging the government’s evidence of willfulness will be a key defense strategy in many cases, we have also had success challenging the government’s evidence that our clients violated the Internal Revenue Code.
Payroll Tax Evasion and Fraud
Payroll tax compliance has been a recent enforcement priority for IRS CI and the DOJ as well. This is due in large part, though not exclusively, to the widespread fraud perpetrated under the pandemic-era Employee Retention Credit (ERC) program and Paycheck Protection Program (PPP). Similar to income tax evasion and tax fraud, allegations of willful payroll tax evasion or tax fraud can expose corporations and their personnel to substantial penalties.
Offshore Tax Fraud
Offshore tax fraud is another longstanding priority enforcement area for IRS CI. Under the Bank Secrecy Act and Foreign Account Tax Compliance Act (FATCA), U.S. taxpayers have an obligation to disclose their foreign financial accounts and other foreign financial assets to the U.S. Department of the Treasury annually. For most taxpayers—both individual and corporate—this means both filing Form 8938 with the IRS and filing a Report of Foreign Bank and Financial Accounts (FBAR) with the Financial Crimes Enforcement Network (FinCEN). While many offshore disclosure violations are civil in nature, the Bank Secrecy Act and FATCA violations can also trigger criminal allegations in some cases.
Corrupt Corporate Practices
Along with federal tax crimes, IRS CI also targets other types of corporate crimes. This includes working alongside the DOJ and other authorities in the U.S. and abroad to uncover and prosecute corporate corruption. Allegations of corporate corruption can vary widely, from engaging in anticompetitive commercial practices to attempting to bribe domestic or foreign government officials. Corporate corruption charges also carry substantial penalties for both entities and individuals, and when targeted with these charges, a proactive and intelligent defense is critical for avoiding unnecessary consequences.
Other Corporate Crimes
Beyond corporate corruption, IRS CI investigates a wide range of other corporate crimes as well. At Brown, P.C., we have extensive experience defending corporate entities and individuals against an extremely wide range of criminal allegations. If you need a Texas business tax attorney to assist with responding to any of the following types of allegations, we encourage you to contact us promptly for more information about our experience and results:
- Accounting Fraud
- Investor Fraud
- Mail Fraud and Wire Fraud
- Money Laundering
- Securities and Commodities Fraud
Strategic Defense for Corporate Tax Crime Investigations
When you engage a Texas IRS criminal investigation lawyer at Brown, P.C., your lawyer will work quickly to assess the allegations at issue and formulate a targeted and cohesive defense strategy. Our primary goal in all cases is to protect our clients against facing formal criminal charges. To achieve this outcome, we work quickly to intervene in IRS CI’s or the DOJ’s investigation, understand the full scope of the investigation, and then examine both the relevant facts and the relevant law. This approach has proven extremely successful, and we take pride in protecting our clients against business-threatening or life-altering consequences.
Speak with a Texas Business Tax Attorney at Brown, P.C. in Confidence
If you would like to know more about our corporate tax crimes practice, we invite you to get in touch. Please call 888-870-0025 or contact us online to request an appointment with a Texas business tax attorney at Brown, P.C.