Tax Matters

Collora LLP has represented clients in a variety of governmental inquiries, investigations and enforcement actions involving tax issues.

Because actions taken during the course of an ordinary tax audit can result in an expanded probe or a serious criminal charge, it is important to have input from an experienced lawyer prior to dealing with the government’s auditors. Our firm knows the trigger points and concerns of taxing authorities and prosecutors because we have lawyers with experience in both prosecution and defense of tax-related actions. Thus, we can offer to clients the effective strategic counseling that can avoid a government charge.

Our lawyers not only understand the decision-making process for the government, they know what kinds of deals can and can’t be made without bureaucratic approvals, and they know, in a worst-case scenario, the kinds of extenuating circumstances that must be demonstrated in a successful plea for a civil remedy or for criminal leniency.

We can also assist clients to comply with periodic voluntary income disclosure programs that may result in clemency or leniency, such as the 2010 program instituted for voluntary disclosure of off-shore bank accounts in Switzerland and elsewhere.

The following shows the kinds of clients we have represented in government enforcement actions related to tax matters, as well as some of the industries of our clients, the legal issues we have handled and the representative results that we have obtained. (For information about our experience with other government enforcement matters, see the links at the bottom of this page.)

Clients

Collora LLP lawyers have represented a variety of clients in inquiries, investigations and enforcement actions related to tax matters, including but not limited to:

  • Corporations
  • Partnerships
  • Executives
  • Brokers
  • Sales Professionals
  • Other Individual Taxpayers

Industries

Our lawyers have represented clients in tax matters related to a variety of industry sectors, including but not limited to:

  • Automotive Sales
  • Financial Services
  • Food and Beverage Services
  • Insurance
  • Mortgage Services
  • Real Estate and Construction

Issues

Our lawyers have successfully dealt with a variety of issues associated with investigations and enforcement actions pertinent to tax matters, including but not limited to the following:

  • Aiding and Abetting Allegations
  • Failure to File Return Issues
  • Failure to Withhold Payroll Tax Charges
  • False Return Allegations (including issues re: expense vs. capital classifications)
  • Illegal Off-shore Tax Shelter Issues
  • Money Laundering Allegations
  • Tax Conspiracy Charges
  • Tax Evasion Charges
  • Tax Return Preparation Issues

Results

The following summaries are a representative sampling of results we have produced for our clients in matters involving civil and criminal government enforcement actions related to tax statutes and regulations.

  • Successfully represented international food services company in federal criminal tax probe related to an acquired company. Resolved the matter with no criminal charge against the client, and obtained reimbursement of civil fine and legal expenses from selling shareholders and lawyers of the acquired company which pleaded guilty.
  • Successfully represented major real estate developer in hearings before the IRS regarding proper expense or depreciation of capital and non-capital items, persuading the examiner that charges of fraudulent misclassification were not appropriate or necessary.
  • Successfully managed grand jury investigations, representing witnesses or companies with potential exposures, and ultimately avoiding any criminal indictment or penalty.

For more information about our experience with other kinds of government enforcement matters, click on any of the pertinent links below.