A relatively new federal tax statute (Internal Revenue Code section 7623) authorizes the Internal Revenue Service to pay a whistleblower a fee for providing “specific and credible” information that substantially contribute to the determination and collection of tax. The whistleblower award is a contingent fee ranging between 15 to 30 percent of the amount collected. The minimum amount collected for the tax whistleblower award is $2,000,000. Accordingly, this program is designed to encourage individuals who have information that a person, corporation, trust, entity, or organization has not properly reported or paid its federal tax liability. The types of tax included in the whistleblower program include all federal taxes, such as (1) individual income tax, (2) corporate income tax, (3) trust income tax, (4) pension plan qualification, (5) exempt entities, (6) charitable organizations non-exempt income, (7) employment tax, (8) excise tax, (9) gift tax, (10) estate tax, and (11) other federal taxes.
Often the tax whistleblower program includes information regarding unreported or underreported income schemes, income allocated to an off-shore or foreign entity, falsely claimed tax deductions, falsely claimed tax credits, and assets in the name of another person or entity (nominee) or assets hidden off-shore. While there is generally no collection power outside the United States, there are various legal tools which a skilled lawyer may utilize to require a taxpayer to repatriate his or her assets to the United States and pay his or her federal tax liability.
A tax controversy attorney can assist a tax whistleblower submit his or her claim to increase the likelihood that the information will result in an audit and ultimately that the additional tax deficiency will be upheld during an administrative appeal or court challenge. The package submitted by this law firm will include a turn-key additional tax proposal, similar to and IRS auditor’s work paper final write-up, including (1) a detailed discussion of the facts, (2) copies of the appropriate and important documents, records, contracts, and other agreements, (3) legal analysis explaining the federal tax law with appropriate citations to legal authorities, Internal Revenue Code section, Treasury Regulations, IRS notices, and court opinions.
Our goal is to increase the opportunity that your case will be accepted by the Internal Revenue Service Whistleblower Office and also increase the contingent fee amount from the 15% lower end range toward the higher 30% range.
This office can litigate a tax whistleblower award against the Internal Revenue Service in a manner to protect your confidentiality.
Being a whistleblower is stressful. First, the whistleblower is most likely an insider (current employee or family member). Filing a whistleblower claim may financially injure the taxpayer (your employer, friend, or family). Moreover, the whistleblower may be so intimately involved in the case, such that the whistleblower may, after providing so much useful information, become the target of a government investigation. A whistleblower must proceed with caution. A whistleblower should consult with a tax controversy lawyer.