Corporate Tax Attorney - Federal Lawyer

Corporate Tax Attorney

Outside Tax Counsel for Companies Facing Scrutiny from the IRS, IRS CI, and DOJ

Alina Veneziano
Attorney Alina Veneziano
Corporate Tax Attorney & CPA Team Lead
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Nick Oberheiden
Attorney Nick Oberheiden
Corporate Tax Attorney Team Lead
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Corporate tax fraud has long been among the Internal Revenue Service’s (IRS) top enforcement priorities. Along with conducting corporate tax audits, the IRS and its Criminal Investigation division (IRS CI) also work alongside the U.S. Department of Justice (DOJ) to pursue criminal charges against corporations—and their owners and executives—when warranted. At Oberheiden P.C., our corporate tax lawyers and consultants rely on extensive experience to effectively represent corporations, limited liability companies, tax exempt organizations, nonprofit organizations, and individuals in all types of federal tax-related matters.

This includes experience inside the IRS and the DOJ. Before entering private practice, several of our corporate tax lawyers prosecuted tax fraud, tax evasion, and other financial crimes as U.S. Attorneys and Assistant U.S. Attorneys in federal jurisdictions across the United States. Our defense team also includes former Special Agents with IRS CI. As a result, we are intimately familiar with the government’s tax-related enforcement priorities and tactics, and we are able to rely on this familiarity to execute proactive and efficient defense strategies on behalf of our clients.

Corporate Tax Matters We Handle

We represent corporations and their owners and executives in all federal tax aspects and tax issues involving the IRS, IRS CI, DOJ, and other federal law enforcement authorities. We also advise corporate clients on tax strategies and comprehensive tax planning, helping them implement effective tax advice and mitigation strategies that avoid crossing the line from lawful tax avoidance to unlawful tax evasion. Uncovering and prosecuting abusive tax shelters is among the IRS’s top priorities within the broader umbrella of corporate tax fraud, and we have the experience and insights required to both help corporations avoid abusive practices and defend against allegations of implementing abusive tax shelters when necessary.

Representative examples of corporate tax matters we handle include:

Corporate Tax Strategy and Abusive Corporate Tax Shelter Defense

We work with corporations’ in-house accounting departments and outside tax advisors to help them implement lawful corporate tax mitigation strategies. Each corporate tax lawyer at Oberheiden P.C. has extensive experience evaluating both proposed and existing corporate tax strategies, and we are available to provide advice and opinions regarding corporate compliance with the Internal Revenue Code, Bank Secrecy Act, Foreign Account Tax Compliance Act (FATCA), and other pertinent federal laws and regulations.

Our corporate tax attorneys also represent companies facing allegations of leveraging abusive tax shelters during IRS audits and federal tax-related investigations. This includes allegations such as:

  • Abusive business credit and deduction claims
  • Abusive micro-captive insurance arrangements
  • Abusive monetized installment sales
  • Abusive syndicated conservation easements
  • Abusive use of the U.S.-Malta tax treaty

These are just examples. If your company is facing allegations of leveraging any type of abusive tax shelter or scheme, we can use our experience to work effectively with the IRS (or IRS CI) on your company’s behalf. Depending on the circumstances, we can either focus on affirmatively demonstrating compliance or employing other defense tactics as necessary.

Corporate Income Tax Fraud and Tax Evasion Defense

We defend corporations facing allegations of income tax fraud and tax evasion during audits, investigations, and federal law enforcement proceedings. We also defend corporate owners and executives who are facing allegations of tax fraud, tax evasion, and other federal crimes. These are extremely high-risk matters that require a highly strategic approach, and we have a proven track record of achieving favorable resolutions for our clients.

Cryptocurrency Tax Fraud and Tax Evasion Defense

The IRS and IRS CI are both paying particular attention to tax fraud and tax evasion involving cryptocurrency. It has now been several years since the IRS implemented its cryptocurrency-specific disclosure requirements, and the IRS and IRS CI are leveraging both traditional investigative tools (i.e., “John Doe” subpoenas to cryptocurrency exchanges) and new technologies to determine when cryptocurrency-related audits and investigations are warranted. We have particular experience in this area as well, and our attorneys have published one of the leading books on the law of blockchain technology.

Employment Tax Fraud Defense

Corporations can face civil and criminal allegations involving a wide range of employment tax-related offenses. This includes everything from claiming false payroll expenses to failing to remit employment taxes held in trust and improperly claiming the pandemic-era Employee Retention Credit (ERC). Our corporate tax lawyers have extensive experience in this area as well; and, here too, we take a proactive approach to helping our corporate clients achieve favorable resolutions that avoid federal prosecution.

International Tax Fraud Defense

Corporations that operate in multiple countries, that deliver products or services across international borders, and that have bank accounts and other assets offshore owe unique reporting and disclosure obligations to the IRS. International tax violations can expose corporations (and their owners and executives) to steep civil or criminal penalties. We assist corporations and individuals with international tax compliance, including proper utilization of foreign tax credits, and provide representation for audits and investigations under the Bank Secrecy Act, FATCA, and other relevant federal statutes.

IRS Technical Advice and Private Letter Ruling Requests

For corporations contemplating large-scale acquisitions and other complex transactions, requesting technical advice or a private letter ruling from the IRS can be an effective way to mitigate the tax-related risks involved. We help our clients understand when these requests are warranted; and, when they are warranted, we prepare and submit them to the IRS on our clients’ behalf.

Streamlined Filing Compliance and Voluntary Disclosure

Streamlined filings and voluntary disclosures are tools that corporations (and individuals) can use to proactively address civil and criminal tax law violations. However, submitting a streamlined filing or voluntary disclosure can also be very risky. As a result, an informed and strategic approach is essential; and, at Oberheiden P.C., our corporate tax attorneys rely on their extensive experience to assist our corporate clients with these matters as well.

Put our highly experienced team on your side

Dr. Nick Oberheiden
Dr. Nick Oberheiden



Lynette S. Byrd
Lynette S. Byrd

Former DOJ Trial Attorney


Brian J. Kuester
Brian J. Kuester

Former U.S. Attorney

Amanda Marshall
Amanda Marshall

Former U.S. Attorney

Local Counsel

Joe Brown
Joe Brown

Former U.S. Attorney

Local Counsel

John W. Sellers
John W. Sellers

Former Senior DOJ Trial Attorney

Linda Julin McNamara
Linda Julin McNamara

Federal Appeals Attorney

Aaron L. Wiley
Aaron L. Wiley

Former DOJ attorney

Local Counsel

Roger Bach
Roger Bach

Former Special Agent (DOJ)

Chris Quick
Chris J. Quick

Former Special Agent (FBI & IRS-CI)

Michael S. Koslow
Michael S. Koslow

Former Supervisory Special Agent (DOD-OIG)

Ray Yuen
Ray Yuen

Former Supervisory Special Agent (FBI)

Why to Choose the Corporate Tax Lawyers at Oberheiden P.C.

If your company needs outside federal tax counsel, why should you choose the corporate tax attorneys at Oberheiden P.C. over other law firms? Here’s what we offer:

  • Senior Corporate Tax Lawyers and Consultants – When you choose Oberheiden P.C., all members of your company’s defense team will be senior-level corporate tax attorneys and consultants.
  • Experience at IRS CI – The consultants on your company’s defense team will include former Special Agents with IRS CI.
  • Experience at the DOJ – The corporate tax lawyers on your company’s defense team will include former U.S. Attorneys and Assistant U.S. Attorneys with the DOJ.
  • Effective Communication and Strategies – We prioritize effective communication, and we develop and execute effective strategies that target specific favorable results.
  • Proven Results in High-Stakes Federal Matters – Our strategic approach to high-stakes corporate tax matters has resulted in a proven record of success.

FAQs: Understanding the Risks of Corporate Tax Audits and Investigations

What Are the Penalties for Corporate Tax Evasion and Tax Fraud?

The penalties for corporate tax evasion and tax fraud depend on the specific allegations and circumstances involved. Broadly, corporations targeted in IRS audits and IRS CI investigations can face liability for back taxes, interest, and fines—with the aggregate fines alone often far exceeding $1 million.

When Can Corporations Face Criminal Tax Investigations?

Corporations can face criminal tax investigations when revenue agents at the IRS or Special Agents with IRS CI have reason to believe that they have engaged in intentional tax evasion or tax fraud. Concerns about intentional income tax fraud, employment tax fraud, international tax fraud, and other tax-related violations and financial crimes can all trigger criminal scrutiny.

What Can Trigger a Criminal Corporate Tax Fraud Investigation?

Criminal corporate tax fraud investigations can have several triggers. Frequently, criminal investigations flow from corporate tax audits that uncover evidence of potential willful misconduct. However, whistleblower complaints from disgruntled employees, information shared by other targets, and other third-party disclosures can trigger criminal investigations as well. For companies that are under investigation, determining what triggered the investigation is a key first step toward executing a strategic defense.

How Can Corporations Avoid Facing IRS (or IRS CI) Scrutiny for Federal Tax Violations?

When corporations need to remedy federal tax violations, a proactive approach is critical. Once the IRS initiates an audit (or IRS CI launches an investigation), several otherwise-viable options go off of the table. Depending on the circumstances, a streamlined filing or voluntary disclosure may be warranted, or it may be necessary to take other steps to avoid triggering IRS (or IRS CI) scrutiny.

When Should Corporations Engage Outside Federal Tax Counsel?

Corporations should engage outside federal tax counsel promptly upon identifying any potential federal tax-related concerns. At Oberheiden P.C., we work closely with corporate clients to help them make informed and strategic decisions focused on maintaining tax compliance, and we defend corporate clients during audits, investigations, and federal criminal prosecutions when necessary. If you have any corporate tax-related questions or concerns, we invite you to contact us for a complimentary consultation.

Speak with a Senior Corporate Tax Attorney at Oberheiden P.C. in Confidence

To schedule a complimentary consultation with a senior corporate tax lawyer at Oberheiden P.C., please call 888-680-1745 or contact us online. We will arrange for you to speak with one of our senior attorneys in confidence as soon as possible.

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