Tax Crimes Without Borders: A Case Study
in Navigating Criminal Tax Exposure in
the EU and U.S. from Sensitive Audits to
Indictments

26th Annual U.S. and Europe Tax Practice Trends, Rome

As global tax authorities ramp up scrutiny and cooperation, the line between a complex, sensitive civil audit and a criminal tax investigation has never been more difficult to identify. This panel uses a real-world- inspired case study with the panelists playing key roles to explore the high-stakes journey of a taxpayer facing parallel scrutiny in both the European Union and the United States. Our expert panelists—comprising seasoned defense counsel and former government officials—will guide you through the critical stages of a cross-border tax controversy. Key topics include:

• The “Sensitive” Audit: Identifying the key signs that signal a civil exam is transitioning into a criminal inquiry.

• Strategic Defense in Dual Jurisdictions: Navigating the procedural differences between U.S. IRS-CI investigations and EU enforcement agencies, including the European Public Prosecutor’s Office (EPPO).
• Information Exchange & Cooperation: How tax authorities now use treaties, MLATs, and joint task forces to “connect the dots” across borders.
• Managing Indictments: Practical strategies for defending against multi-jurisdictional charges, from managing evidence to negotiating global resolutions.

Attendees will gain actionable insights into the latest enforcement trends and the coordinated defense strategies essential for protecting clients in an era of unprecedented international transparency.