When tax examinations do not conclude with an agreement with tax authorities, we represent clients in administrative appeals and in court in a wide variety of matters involving federal and state taxes. These include individual and corporate income tax, employment taxes, estate and gift taxes, sales and use taxes, real property taxes and tax exemptions.
We regularly represent clients facing the possibility--or reality--of investigation or prosecution for alleged criminal tax offenses, including alleged omission of income, improper deductions, failure to disclose foreign accounts or other alleged improprieties. We counsel clients attempting to minimize or reduce the likelihood of criminal prosecution, whether the client is already the subject of a criminal investigation or is concerned about discovery of tax improprieties due to disclosure by a third party or a civil tax audit. We also guide clients though the process of voluntary disclosure of foreign accounts, omission of income or other tax improprieties. Where a criminal investigation or indictment cannot be avoided, Cole Schotz represents clients with the administrative criminal investigation agencies, the prosecutors’ offices and in court.