Nevada Tax Attorney - Federal Lawyer

Nevada Tax Attorney

Nevada address – by appointment only:
5940 S. Rainbow Boulevard
Las Vegas, NV 89118
702-213-9490

Former DOJ Prosecutors Representing Nevada Residents and Businesses in Federal Tax Matters

Alina Veneziano
Attorney Alina Veneziano
Nevada Tax Attorney & CPA Team Lead
envelope icon Contact Alina
Nick Oberheiden
Attorney Nick Oberheiden
Nevada Tax Attorney Team Lead
envelope icon Contact Nick

Facing scrutiny from the Internal Revenue Service (IRS) or IRS Criminal Investigation (IRS CI) can present substantial risks for high-net-worth individuals and businesses. Not only can audits and investigations lead to liability for back taxes and interest, but they can also expose individual and corporate taxpayers to civil or criminal penalties. As a result, a cautious approach to federal tax compliance is critical; and, when facing scrutiny from the IRS or IRS CI, targeted taxpayers need to work with an experienced Nevada tax lawyer, experienced with federal tax law, who can help protect them by all means available.

At Oberheiden P.C., our experienced tax lawyers rely on extensive federal experience to advise and represent Nevada residents and businesses in all IRS-related tax matters. Whether you have questions about implementing a federally compliant tax mitigation strategy or you are facing an audit or investigation, we can guide you confidently forward. Each Nevada tax lawyer at our firm has senior-level experience, and many of our attorneys previously prosecuted tax fraud and other white-collar crimes at the U.S. Department of Justice (DOJ). With former IRS CI Special Agents on our team as well, we are fully equipped to help high-net-worth individuals and companies make informed decisions and avoid unnecessary liability.

Federal Tax Matters We Handle

Within our federal tax practice, we represent a wide range of clients in the areas of compliance, enforcement, and defense. We take a sophisticated and custom-tailored approach to our federal tax practice that focuses on maximizing each client’s tax savings while simultaneously minimizing each client’s risk.

When you engage Oberheiden P.C. to represent you or your company, you will work closely with a senior Nevada tax attorney who will work quickly to get fully up to speed on the status of your (or your company’s) federal tax filings. This lawyer will serve as your primary point of contact; however, you will have access to—and you will benefit from the experience and insights of—all members of our federal tax team. Contact us today to learn more about our representation for:

  • Complex Federal Tax Planning and Compliance
  • IRS Audits
  • IRS CI Investigations
  • Streamlined Filing Compliance
  • Voluntary Disclosure
  • IRS Appeals and Tax Court Litigation
  • Criminal Tax Fraud and Tax Evasion Litigation 
  • Offers in Compromise
  • IRS Settlement Negotiations
  • Asset Forfeitures and Other Federal Tax Enforcement Matters

Put our highly experienced team on your side

Dr. Nick Oberheiden
Dr. Nick Oberheiden

Founder

Attorney-at-Law

Lynette S. Byrd
Lynette S. Byrd

Former DOJ Trial Attorney

Partner

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)

Common Issues in Federal Tax Audits and Investigations

While the IRS and IRS CI enforce all aspects of federal tax compliance, we have seen a large number of audits and investigations focusing on a specific subset of issues in recent years. These issues align with the IRS and IRS CI’s stated enforcement priorities, and we expect to continue to see a high level of enforcement in these areas in the years to come. Examples include:

High-Net-Worth Taxpayer Income Tax Compliance

The IRS and IRS CI are focusing on targeting high-net-worth taxpayers in audits and investigations. In an effort to close the tax gap, the IRS and its criminal enforcement arm have shifted focus to enforce compliance among the highest earners. In these audits and investigations, the IRS and IRS CI are focusing on issues such as:

  • Utilizing abusive tax shelters and tax schemes
  • Underreporting taxable income
  • Claiming fraudulent deductions and exemptions

These issues—among many others—can expose high-net-worth taxpayers to substantial liability. If revenue agents or IRS Special Agents have reason to believe that a taxpayer’s improper reporting or payment was intentional, these types of issues can also lead to criminal tax fraud and tax evasion allegations.

Business Income and Employment Tax Compliance

Along with targeting high-net-worth individuals (including business owners and executives), the IRS and IRS CI are also targeting businesses that file suspicious returns. They are targeting both income and employment tax compliance, placing particular emphasis on issues such as:

  • Business income underreporting and invalid business expense deductions
  • Improper employment taxes calculations
  • Failure to withhold or remit employees’ FICA taxes

Just like individuals, businesses targeted in federal tax enforcement matters can face both civil and criminal penalties. When we represent businesses in high-stakes federal tax matters, our Nevada tax lawyers focus on keeping the IRS’s inquiry civil in nature, and we focus on limiting our clients’ liability to the greatest extent possible.

Pandemic-Era Tax Evasion and Tax Fraud (PPP, EIDL, and ERC Fraud)

Pandemic-era tax evasion and tax fraud remain top enforcement priorities for the IRS and IRS CI. This includes fraudulent claims and filings under the Paycheck Protection Program (PPP), Economic Injury Disaster Loan (EIDL) program, and Employee Retention Credit (ERC). Enforcement actions involving alleged PPP, EIDL, and ERC fraud are increasingly criminal in nature; and, in criminal cases, IRS CI and the DOJ are pursuing charges for multiple offenses that carry the potential for both substantial fines and long-term imprisonment. If the IRS or IRS CI is looking into your (or your company’s) PPP, EIDL, or ERC filings, it is important that you speak with an experienced Nevada tax attorney as soon as possible.

Cryptocurrency Tax Evasion and Tax Fraud

Cryptocurrency-related income tax compliance remains a top enforcement priority for the IRS and IRS CI as well. As cryptocurrency investing has gone mainstream—with several apps now allowing investors to trade Bitcoin and other cryptocurrencies instantly on their phones—the IRS and IRS CI have ramped up their efforts to enforce taxpayers’ reporting and payment obligations at all income levels (with particular emphasis on high-income taxpayers). Along with examining taxpayers’ returns for signs of cryptocurrency-related tax violations, IRS CI is also relying on “John Doe” subpoenas and other investigative tools to obtain cryptocurrency investors’ identities from exchanges and other sources.

Offshore Account and Foreign Financial Asset Disclosure Violations

International tax compliance is a perennial enforcement priority for the IRS and IRS CI as well, once again with particular emphasis on high-net-worth taxpayer compliance. Failure to properly disclose offshore accounts or other foreign financial assets is a common trigger for both IRS audits and IRS CI investigations, and these inquiries can expose taxpayers to substantial fines and other penalties. While submitting a streamlined filing or voluntary disclosure is an option for taxpayers who are not yet facing scrutiny, once an audit or investigation is underway, avoiding unnecessary consequences involves engaging an experienced Nevada tax lawyer to work with the IRS or IRS CI on your behalf.

FAQs: Avoiding Unnecessary Consequences in IRS Audits and IRS CI Investigations

Do I Need a Nevada Tax Lawyer if I am Facing an IRS Audit?

When facing an IRS audit, it is essential to ensure that you are making informed decisions based on an accurate understanding of your (or your company’s) tax liability and the accuracy of the filings in question. Ensuring that you are making informed decisions involves working with experienced tax counsel. At Oberheiden P.C., each Nevada tax attorney at our law firm has extensive experience advising clients in high-stakes federal tax matters, and our former DOJ prosecutors and IRS CI Special Agents can provide the insights you need to avoid unnecessary consequences.

What Does It Mean if I Have Been Contacted By IRS Criminal Investigation?

If you have been contacted by IRS Criminal Investigation, this generally means one of two things—either (i) IRS CI is seeking information in support of an investigation into a third party; or, (ii) you are the target of a criminal tax fraud or tax evasion investigation. In either scenario, it is critical to ensure that you both meet your obligations and do what is necessary to protect yourself, and this also requires the advice of experienced tax counsel.

What Penalties Can I Face in an IRS Audit?

The penalties taxpayers can face during IRS audits vary depending on the specific violations at issue (if any). The IRS imposes different penalties for failure to file, failure to pay your tax debts, underpayment, and other violations of the Internal Revenue Code. In all cases, however, taxpayers who have outstanding tax debt owe interest as well—and both interest and penalties begin accruing immediately upon the commission of a violation.

What Penalties Can I Face in an IRS CI Investigation?

If you are facing a criminal tax fraud or tax evasion investigation, not only are you facing substantial fines, but you are facing federal prison time as well. When we represent clients during IRS CI investigations, our Nevada tax lawyers focus on keeping our clients out of prison while minimizing their potential financial liability to the greatest extent possible.

How Can I Avoid Liability for Tax Evasion or Tax Fraud?

Avoiding liability for tax evasion or tax fraud starts with putting an experienced Nevada tax attorney on your side. If you have concerns about your federal tax filings, if you are facing an IRS audit, or if you have received a subpoena or target letter from IRS CI, we encourage you to contact us promptly for more information.


Speak with a Senior Nevada Tax Lawyer at Oberheiden P.C. in Confidence

Our practice area is not limited to Las Vegas, NV. Whether you’re in Las Vegas, Reno, Mountain City, or anywhere in between, if you would like to speak with a senior Nevada tax attorney at Oberheiden P.C., we invite you to get in touch. To schedule a complimentary consultation, call 888-680-1745 or contact us confidentially online today.

WordPress Lightbox