IRS Whistleblower Program for Tax Whistleblowers
Since December 2006, tax whistleblowers who report tax fraud, tax evasion, and other tax liability of at least $2 million can receive awards of 15% to 30% of the amount recovered by the IRS. Our law firm was one of the first to submit tax whistleblower claims under the new IRS Whistleblower Program.
Our whistleblower attorneys have submitted many billions of dollars in tax whistleblower claims. We have documented and exposed a wide range of tax violations–from simple tax fraud within the United States, to multi-billion dollar claims involving complex foreign and offshore tax evasion.
We work with a team of the most experienced former IRS criminal and civil agents, forensic accountants, and tax lawyers with both international and U.S. tax expertise.
As former federal prosecutors who have also defended criminal tax cases, we develop fully for the IRS both the factual and legal arguments needed to support our client’s claims. To assist the IRS, we develop an investigative plan for each case that the IRS can pursue to make the claim successful.
Our clients also take comfort in knowing that, unlike some other firms, our lawyers have both civil and criminal trial backgrounds. We are experienced in helping clients evaluate and minimize any risk to them of criminal prosecution, based on our white collar prosecution and defense backgrounds. We have also presented programs on protecting whistleblowers from criminal and civil liability, a timely topic in light of the UBS case.
The IRS Whistleblower Office knows from experience that, when it receives any claim from our firm, that claim has been well-researched, well-documented, and well-presented. We are selective in the claims we pursue, and are demanding of ourselves in pursuing them. Over the years we have succeeded in earning our credibility with the IRS.
Specific examples of tax fraud, tax evasion, and other tax violations we have worked with in our IRS Whistleblower practice include:
- Unreported Offshore Income
- Unreported Subpart F Income
- Abusive Tax Schemes and Tax Shelters
- Transfer Pricing
- Untaxed U.S. Branches of Foreign Corporations
- Unlawful Manipulation of Net Operating Losses (NOL) and Other Tax Attributes
- Unlawful Basis Manipulation
- Understatement of Income
- Overstatement of Deductions and Credits
Since 2007, we also have worked each year with the IRS Whistleblower Office senior staff in presenting programs to educate lawyers on the best practices in pursuing tax whistleblower claims. Also since 2007, we also have kept other lawyers and the public informed about major developments in the evolving IRS Whistleblower Program with information we compile on our blog.
We also advocate for tax whistleblowers. In 2011, we argued at an IRS public hearing for important changes to the proposed IRS whistleblower rules. We are committed to ensuring that the new tax whistleblower program fulfills its potential—by attracting and rewarding whistleblowers who have the most significant information.