Criminal and Investigations Tax

Overview

Crowell’s Tax Compliance and Reporting team assists clients with all facets of their civil and criminal tax investigation and defense needs by learning their businesses, collaborating with them, and keeping them informed and involved from initial scoping to final resolution. By combining the experience of career defense attorneys, seasoned investigators, former prosecutors, and regulators with creativity and flexibility, we are able to efficiently and effectively defend our clients’ most pressing tax investigations.

More than a quarter of Fortune 100 companies have turned to Crowell & Moring for investigations work. Our team has handled numerous high‐profile tax disputes, achieving optimal outcomes for large corporations, small business owners, executives, trustees, and many other clients in civil and criminal tax matters. Our defense efforts include:

Secured the declination of criminal charges against small business owner for underreporting business income by establishing credible evidence of good‐faith reliance on tax preparer’s advice.
Negotiated a civil penalty and no criminal charges for an investment banker affiliated with a well‐known financial institution who allegedly failed to report a significant amount of income associated with a large transaction in which others were convicted of fraud.
Represented accused double‐agent in highly publicized espionage case, securing dismissal of all charges based on prosecutorial misconduct and negotiating a global resolution of all criminal and tax matters and the return of most of the client’s seized assets.
Defended founder and executive director of a high‐performing charter school against charges of tax fraud, misappropriation of public funds, embezzlement, and conflict of interest.
Prepared comprehensive report addressing allegations of shareholder tax fraud and insider trading claims for the special committee of a photography company’s Board of Directors following its unrealized pivot to a pharmaceutical venture during the COVID‐19 pandemic.
Represented trustees and beneficiaries of foreign trusts in two of the largest international tax collection efforts to date.
Represented a top art museum in an internal investigation of accusations against its director of tax fraud.
Represented a global supplier of nuclear power facilities and an international pharmaceutical company in a NJ Attorney General inquiry into potential fraud in a tax incentives program.