As a greater emphasis is placed on tax-related accountability, companies, directors, officers, employees, and individuals are facing increasing government scrutiny and more severe criminal and civil penalties. Hodgson Russ’s tax investigations and defense attorneys draw on their knowledge of federal, state, and New York City tax laws as they respond to subpoenas and investigative demands from the IRS, New York State Department of Taxation and Finance, and the New York City Department of Finance.

Our goal is to use our experience and creativity to resolve tax issues before charges are filed and investigations become public. When litigation is necessary, our clients benefit from our extensive experience appearing before courts at all levels.

Our attorneys provide representation in grand jury proceedings, federal and state investigations, and revenue crimes bureau and special investigation unit examinations. They also defend clients at depositions and interviews, represent clients during state tax residency audits and IRS examinations, and counsel clients about their obligations under various government regulatory guidelines.

Our Experience

  • Income tax
  • Corporate tax 
  • Sales and use tax 
  • Tax shelter abuses
  • Money laundering and check kiting
  • Unreported income and fictitious expenses
  • Evasion
  • The misappropriation of sales tax and employment tax trust funds
  • Tax fraud
  • Non-filing
  • Employee misclassification
  • Payments “off the books”
  • False statements and false claims
  • Department of Labor audits
  • Foreign bank account reporting

Among the frequently asked questions we receive are:

  • Tax agents have shown up unannounced and want to talk to me or my employees. What should I do?
  • What is a grand jury investigation, and why have I received a subpoena?
  • Investigators are asking questions and requesting documents about me and my business. What does this mean?
  • What is voluntary disclosure, and should I do it?
  • Do I have an innocent-spouse defense?
  • Should I sign consent to extend the statute of limitation?

Prospective clients are urged to seek our counsel before responding to inquiries or making statements to investigators or auditors. Communications with our attorneys are confidential and privileged.

Hodgson Russ has been awarded prestigious “Best Law Firm” rankings by Best Lawyers/U.S. News & World Report in the categories of National Tier 2 Tax Law and Litigation – Tax, Metropolitan Tier 1 Tax Law, and Metropolitan Tier 2 Litigation – Tax.


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Tax Investigations & Defense / News & Insights