For many years tax fraud criminal enforcement took a back seat to Internal Revenue Service (IRS) agents investigating drug-related offenses and money laundering schemes. That has all changed recently. The IRS criminal division is back in business investigating run-of-the-mill tax cases, including but not limited to, aggressive tax shelters, alleged sham transactions to reduce taxable income, and the misreporting of income. Many times, the alleged conduct involves offshore dealings with third parties and complex structured transactions that may or may not have economic substance. We work with tax experts to clearly understand the transactions and issues. In several instances, we have represented professionals such as accountants and lawyers who have been caught up in an investigation and have persuaded prosecutors not to bring charges against them.