Emerging Issues in Criminal Tax Enforcement

Pamela Naughton specializes in internal investigations, complex business litigation, government investigations, and white-collar defense. She is a former Assistant US Attorney and a counsel to the US House Iran/Contra Committee and Judiciary Committee. Ms. Naughton represented "M.H." in the seminal 9th Circuit case on FBAR's required records exception to the 5th Amendment. As first chair, she has tried over thirty jury trials in Federal and State Court. Ms. Naughton is also Former President, San Diego Chapter of the Federal Bar Association. She received her J.D. from Yale Law School in 1979 and her undergraduate degree from St. Olaf College, summa cum laude in 1976.

Matthew D. Lee is a partner in the law firm of Blank Rome LLP and a member of the firm’s White Collar and Government Investigations practice group.  He is a former U.S. Department of Justice trial attorney who concentrates his practice on all aspects of white collar criminal defense, federal tax controversies, and complex civil litigation.  Mr. Lee has represented both corporations and individuals in criminal investigations involving tax, money laundering, health care, securities, public corruption, and fraud offenses, and has significant experience in handling all stages of state and federal litigation including trials and appeals.  He has represented individuals and companies in all stages of proceedings before  the Internal Revenue Service, including audits, appeals, and collections, as well as Tax Court and district court litigation.  Mr. Lee has extensive experience in advising clients on issues regarding foreign bank account reporting (FBAR) obligations, the Foreign Account Tax Compliance Act (FATCA), and the Internal Revenue Service’s 2009 Offshore Voluntary Disclosure Program, 2011 Offshore Voluntary Disclosure Initiative, and 2012 Offshore Voluntary Disclosure Program.  He has represented hundreds of U.S. taxpayers with undisclosed foreign bank accounts.  Mr. Lee has published numerous articles regarding the IRS voluntary disclosure programs and FBAR and FATCA reporting obligations and speaks frequently on these topics.  Mr. Lee also has experience in conducting corporate internal investigations and advising clients as to corporate compliance issues involving the Bank Secrecy Act, the USA Patriot Act, FATCA, and anti-money laundering laws and regulations.  Mr. Lee publishes a blog entitled Tax Controversy Watch (www.taxcontroversywatch.com) which provides timely reviews of the latest developments in the tax controversy field, including criminal tax investigations and prosecutions, civil audits, appeals, and collections matters, and Tax Court and district court litigation.