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When an investigation is already underway, we have had great success representing clients at each stage of the criminal tax process, whether they were facing administrative investigations conducted by IRS agents, joint IRS-DOJ grand jury investigations, or prosecutions by U.S. attorneys’ offices.

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When an investigation is already underway, we have had great success representing clients at each stage of the criminal tax process, whether they were facing administrative investigations conducted by IRS agents, joint IRS-DOJ grand jury investigations, or prosecutions by U.S. attorneys’ offices.

We take this national-international approach because tax enforcement is no longer limited within U.S. borders. The IRS receives a treasure trove of data from U.S. and foreign sources, and it partners with industry experts, the U.S. Department of Justice (DOJ), the U.S. Securities and Exchange Commission (SEC), and increasingly the Joint Chiefs of Global Tax Enforcement to analyze this information.

Start with the basic building block of all narrative.

In a village of La Mancha, the name of which I have no desire to call to mind, there lived not long since one of those gentlemen that keep a lance in the lance-rack, an old buckler, a lean hack, and a greyhound for coursing.

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We take this national-international approach because tax enforcement is no longer limited within U.S. borders. The IRS receives a treasure trove of data from U.S. and foreign sources, and it partners with industry experts, the U.S. Department of Justice (DOJ), the U.S. Securities and Exchange Commission (SEC), and increasingly the Joint Chiefs of Global Tax Enforcement to analyze this information.

This has significantly elevated and advanced the ability of federal agencies to track individuals and institutions as they seek high-impact prosecutions for tax evasion and money laundering that can result in prison sentences and multimillion-dollar fines. Foreign institutions and individuals assisting or facilitating U.S. tax evasion are also not beyond their reach.

This has significantly elevated and advanced the ability of federal agencies to track individuals and institutions as they seek high-impact prosecutions for tax evasion and money laundering that can result in prison sentences and multimillion-dollar fines. Foreign institutions and individuals assisting or facilitating U.S. tax evasion are also not beyond their reach.

In such a landscape, it is important for individuals and corporations to partner with lawyers with experience in white-collar criminal litigation and tax law and in mounting an effective defense against a complex federal tax investigation.

In such a landscape, it is important for individuals and corporations to partner with lawyers with experience in white-collar criminal litigation and tax law and in mounting an effective defense against a complex federal tax investigation.

Members of BakerHostetler’s Criminal Tax Defense team have served in high-level positions at the DOJ and in the IRS Chief Counsel’s Office. Many have LL.M.s in tax or are CPAs. One team member is a former deputy and acting chief of the Criminal Division at the U.S. Attorney’s Office for the District of New Jersey and in the Criminal Enforcement Section in the DOJ’s Tax Division.

Members of BakerHostetler’s Criminal Tax Defense team have served in high-level positions at the DOJ and in the IRS Chief Counsel’s Office. Many have LL.M.s in tax or are CPAs. One team member is a former deputy and acting chief of the Criminal Division at the U.S. Attorney’s Office for the District of New Jersey and in the Criminal Enforcement Section in the DOJ’s Tax Division.

Our extensive experience, along with our knowledge of the law enforcement agencies that prosecute tax offenses and our relationships with senior officials and agency staff across the country, enables us to take on the most challenging cases and achieve outstanding results. At times, we have even convinced the government to shut down investigations.&nbsp;

Our extensive experience, along with our knowledge of the law enforcement agencies that prosecute tax offenses and our relationships with senior officials and agency staff across the country, enables us to take on the most challenging cases and achieve outstanding results. At times, we have even convinced the government to shut down investigations.&nbsp;

Representative clients

Representative clients

An organized collection of items displayed in a specific order.

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List

<ul class="wp-block-list">
<li>Financial Institutions</li>



<li>Tax Return Preparers</li>



<li>Promoters of Tax-Minimization Products</li>



<li>Captive Insurance Promoters and Sponsors</li>



<li>Entrepreneurs and Their Businesses</li>



<li>Holders of Foreign Bank Accounts</li>
</ul>

core/list-item

List Item

<li>Promoters of Tax-Minimization Products</li>

<li>Captive Insurance Promoters and Sponsors</li>

<li>Entrepreneurs and Their Businesses</li>

<li>Holders of Foreign Bank Accounts</li>

<ul><li>Financial Institutions</li><li>Tax Return Preparers</li><li>Promoters of Tax-Minimization Products</li><li>Captive Insurance Promoters and Sponsors</li><li>Entrepreneurs and Their Businesses</li><li>Holders of Foreign Bank Accounts</li></ul>

Frequently encountered charges

Frequently encountered charges

<ul class="wp-block-list">
<li>Tax Evasion</li>



<li>Filing False Tax Returns</li>



<li>Aiding or Assisting in the Filing of False Tax Returns</li>



<li>Failure to Collect or Pay Over Employment Taxes</li>



<li>Conspiracy to Defraud the United States (Klein Conspiracy)</li>



<li>Obstructing the IRS</li>



<li>Failure to File Tax Returns</li>



<li>Failure to File Reports of Foreign Bank or Financial Accounts (FBAR)</li>



<li>Structuring Currency Transactions</li>



<li>Money Laundering</li>



<li>Mail and Wire Fraud</li>
</ul>

Aiding or Assisting in the Filing of False Tax Returns

<li>Aiding or Assisting in the Filing of False Tax Returns</li>

Failure to Collect or Pay Over Employment Taxes

<li>Failure to Collect or Pay Over Employment Taxes</li>

Conspiracy to Defraud the United States (Klein Conspiracy)

<li>Conspiracy to Defraud the United States (Klein Conspiracy)</li>

Failure to File Reports of Foreign Bank or Financial Accounts (FBAR)

<li>Failure to File Reports of Foreign Bank or Financial Accounts (FBAR)</li>

<li>Structuring Currency Transactions</li>

<ul><li>Tax Evasion</li><li>Filing False Tax Returns</li><li>Aiding or Assisting in the Filing of False Tax Returns</li><li>Failure to Collect or Pay Over Employment Taxes</li><li>Conspiracy to Defraud the United States (Klein Conspiracy)</li><li>Obstructing the IRS</li><li>Failure to File Tax Returns</li><li>Failure to File Reports of Foreign Bank or Financial Accounts (FBAR)</li><li>Structuring Currency Transactions</li><li>Money Laundering</li><li>Mail and Wire Fraud</li></ul>

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<section class="wp-block-contentpilot-expand-more"><div class="wp-block-contentpilot-expand-more__excerpt is-visible" data-selector="expand-more"></div><div class="wp-block-contentpilot-expand-more__full-content" data-selector="expand-more">We take this national-international approach because tax enforcement is no longer limited within U.S. borders. The IRS receives a treasure trove of data from U.S. and foreign sources, and it partners with industry experts, the U.S. Department of Justice (DOJ), the U.S. Securities and Exchange Commission (SEC), and increasingly the Joint Chiefs of Global Tax Enforcement to analyze this information.This has significantly elevated and advanced the ability of federal agencies to track individuals and institutions as they seek high-impact prosecutions for tax evasion and money laundering that can result in prison sentences and multimillion-dollar fines. Foreign institutions and individuals assisting or facilitating U.S. tax evasion are also not beyond their reach.In such a landscape, it is important for individuals and corporations to partner with lawyers with experience in white-collar criminal litigation and tax law and in mounting an effective defense against a complex federal tax investigation.Members of BakerHostetler’s Criminal Tax Defense team have served in high-level positions at the DOJ and in the IRS Chief Counsel’s Office. Many have LL.M.s in tax or are CPAs. One team member is a former deputy and acting chief of the Criminal Division at the U.S. Attorney’s Office for the District of New Jersey and in the Criminal Enforcement Section in the DOJ’s Tax Division.Our extensive experience, along with our knowledge of the law enforcement agencies that prosecute tax offenses and our relationships with senior officials and agency staff across the country, enables us to take on the most challenging cases and achieve outstanding results. At times, we have even convinced the government to shut down investigations.&nbsp;Representative clients<ul><li>Financial Institutions</li><li>Tax Return Preparers</li><li>Promoters of Tax-Minimization Products</li><li>Captive Insurance Promoters and Sponsors</li><li>Entrepreneurs and Their Businesses</li><li>Holders of Foreign Bank Accounts</li></ul>Frequently encountered charges<ul><li>Tax Evasion</li><li>Filing False Tax Returns</li><li>Aiding or Assisting in the Filing of False Tax Returns</li><li>Failure to Collect or Pay Over Employment Taxes</li><li>Conspiracy to Defraud the United States (Klein Conspiracy)</li><li>Obstructing the IRS</li><li>Failure to File Tax Returns</li><li>Failure to File Reports of Foreign Bank or Financial Accounts (FBAR)</li><li>Structuring Currency Transactions</li><li>Money Laundering</li><li>Mail and Wire Fraud</li></ul></div><button class="wp-block-contentpilot-expand-more__more-button is-visible" data-selector="expand-more">View More</button><button class="wp-block-contentpilot-expand-more__less-button" data-selector="expand-more">View Less</button></section>

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Jeffrey H. Paravano

Gregory S. Saikin

John J. Carney

Jonathan R. Barr

Kayley B. Sullivan

Carlos F. Ortiz

Deirdre Farrell

Jessica T. Mingrino

New York

Partner

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Tax-Exempt Organizations and Charitable Giving

<ul>
<li>Represented individuals and corporations in numerous criminal tax investigations, including a large accounting firm and several investors in tax shelter prosecutions brought in the Southern District of New York.</li>
<li>Represented the target of a criminal tax and money laundering grand jury investigation, resulting in the declination of charges by the U.S. Attorney’s Office for the Southern District of Florida.</li>
<li>Represented a pharmacist involved in a multiyear, multimillion-dollar tax evasion scheme prosecuted by the Manhattan District Attorney’s Office, resulting in a probation sentence and no civil fraud penalty.</li>
<li>Represented numerous accounting firms in grand jury and SEC investigations involving their audit practices and their preparation of tax returns.</li>
<li>Represented the target of a criminal tax grand jury investigation, resulting in the declination of charges by the U.S. Attorney’s Office for the District of New Jersey.</li>
<li>Representing individuals and corporations in criminal tax investigations, including a large accounting firm and several investors in grand jury investigations relating to conservation easements brought in the Northern District of Georgia by the Department of Justice Tax Division.</li>
<li>Representing numerous individuals regarding their participation in the IRS Offshore Voluntary Disclosure Program; more specifically, counseled numerous individuals who have funds in foreign accounts not previously reported to the IRS as to whether they should seek amnesty from criminal prosecution by entering the program.</li>
<li>Provided in-house training to several national accounting firms as well as to numerous CPA organizations on issues related to criminal tax investigations.</li>
</ul>

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