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Contents
A tax whistleblower who participated in fraud may still have an IRS award claim. If you entered the figures, prepared the paperwork or handled the payments, we want to understand what you know and how you were involved. Your questions about your own role belong in that conversation, with our whistleblower experts and tax fraud whistleblower lawyers who can assess your circumstances.
This page focuses on the insider who took part in the work behind the tax reporting. Our page on the IRS Whistleblower Program covers ordinary eligibility and how useful information connects to an award.
An insider can explain how a transaction became a number on a return. The person handling the payment, the person recording it and the person preparing the return may each see a different part of the same activity. Your account can connect those parts, including who supplied the figures and what instructions accompanied them. The person who knows why those accounts differ can explain something the documents alone leave unclear.
Payroll makes the distinction tangible. A payroll register records wages and withholding, an employment-tax return reports the obligation, and a tax-account credit records money reaching the government. The IRS’s guidance on outsourced payroll addresses the employer’s continuing responsibilities when a provider handles that work. If your job touched the payroll, we examine where your work sat between calculating the wages and paying the tax.
An IRS award claim connects useful information to money the agency collects. The IRS decides whether to investigate, assess and collect the tax, while its Whistleblower Office evaluates the claim and determines the award. We work with you on the account of the conduct and the information that makes it understandable.
The award claim uses Form 211. We build the account of what happened with you, connecting your firsthand knowledge to the business records.
A whistleblower case under the False Claims Act can pay 15% to 30% of what the government recovers. The IRS program uses the same ordinary range, but federal tax claims follow a separate award process because the federal False Claims Act excludes Internal Revenue Code claims.
The main IRS award program applies when proceeds in dispute exceed $2 million. If the taxpayer being reported is an individual, that person’s gross income must also exceed $200,000 in a relevant tax year. The IRS award framework also allows discretionary awards outside those thresholds. We assess the underlying tax issue and your information together.
We assess your potential IRS award claim with you and tax fraud whistleblower lawyers. If you wonder how the IRS calculates an award reduction for a whistleblower who was a planner or initiator, bring that question to us. We want to hear what you did, what you understood at the time and what the records show about the decisions inside the business. That conversation starts with your experience, including the parts you are unsure how to describe.
Questions about conviction, disqualification or criminal exposure belong in that same conversation if you participated in the tax fraud scheme. We address those concerns with the appropriate tax fraud whistleblower lawyers alongside the potential claim. Questions about your own tax reporting, confidentiality or professional obligations belong in the same careful conversation.
Useful evidence connects a particular taxpayer, tax period and transaction to the tax that went unpaid. The business records can show the payment and accounting treatment, while your explanation supplies who made the decision and how you learned about it. That connection matters when the instruction and the resulting entry sit in different places.
The IRS contribution rules recognize information that helps initiate, expand or continue an enforcement action. The award assessment follows how that information contributes to the action producing collections. A description of the transaction, the relevant records and the reason they matter lets us develop that connection with you. We work through what you know, how you learned it and questions about access with you and the tax fraud whistleblower lawyers handling the matter.
A tax scheme can depend on an appraisal, a sales presentation and a return prepared by different people. In its civil complaint concerning conservation-easement promotions, the Justice Department alleged that EcoVest organized, promoted and sold syndicates and helped secure the land trust, appraiser and deduction paperwork. The complaint alleged that initial valuations overstated the easements’ value and then became part of the sales pitch.
The complaint describes what the valuation was for:
This initial valuation is used to market and sell the LLC interests. The appraisers know that their valuation will be used in this manner.
United States v. Zak, government complaint, Northern District of Georgia, paragraph 61(c)
The Justice Department alleged that the syndicate passed its deduction through to customers. If you worked on the appraisal, marketing materials or return preparation, we want to hear how that claimed value moved between them. In the complaint’s account, the appraisal put a value on the gift. The sales pitch sold the tax deduction.
The Justice Department’s account of a former UBS private-banking director’s guilty plea describes assistance concealing $200 million in client assets and evading $7.2 million in income tax. For someone in banking, account-owner records and transaction histories can supply those connections.
That kind of knowledge reaches beyond reading a return. A banking employee may understand whose money an account holds, how the transactions fit together and what the paperwork obscures. We want to understand that business knowledge alongside your part in the work.
An auditor can see a reported transaction without understanding the arrangement behind it. The 2014 Villanova Law Review article Not Just Whistling Dixie: The Case for Tax Whistleblowers in the States explains how insider knowledge can close that gap. It describes secretive tax-shelter presentations and efforts to hide the arrangements on clients’ returns:
It was precisely the environment where the government needed the help of an insider to have any idea what was happening.
Not Just Whistling Dixie: The Case for Tax Whistleblowers in the States, Villanova Law Review, 2014
Your explanation may connect the transaction’s formal description to the instructions that produced it. If you worked on the documents or payments, that knowledge is part of what we assess with you. The work you understand can make a complicated tax arrangement intelligible to someone outside it.
New York and D.C. allow qualifying tax claims brought by whistleblowers in the government’s name under their own false-claims laws. Those cases are separate from an IRS award claim. The tax jurisdiction is part of the assessment when your information concerns more than a federal return. We examine the state tax issues with you alongside the federal ones. Your work may connect several returns or businesses, and the records help identify which tax obligation the conduct affected.
If you helped prepare the figures, move the money or explain the transaction, speak to our whistleblower experts about what happened and your part in it. We work with you to build your strongest tax whistleblower case, bringing in tax fraud whistleblower lawyers suited to your circumstances and working through your questions about your own role.