Kohn, Kohn & Colapinto obtained the world’s largest Internal Revenue Service (IRS) tax fraud whistleblower reward
Kohn, Kohn & Colapinto is the most successful whistleblower law firm representing IRS whistleblowers. We have won the largest awards, for the most amount of tax whistleblowers. Our cases have set the most important precedents in Tax Court, and we have successfully worked with Congress in amending the tax whistleblower law to cover criminal tax evasion, money laundering, and establishing state-of-the-art anti-retaliation rules.
We represented IRS whistleblower Bradley Birkenfeld, who exposed massive tax frauds at the Swiss bank UBS. He obtained the largest Internal Revenue Service (IRS) tax fraud whistleblower award, Bradley Birkenfeld ($104 million). Mr. Birkenfeld’s disclosures forced Switzerland to change its international treaty with the United States and disclose, for the first time in history, the names of over 4,900 U.S. citizens who held illegal offshore accounts.
Professor Dennis Ventry, Jr., a leading tax expert and a member of the IRS’s Tax Advisory committee, explained the full impact of Mr. Birkenfeld’s whistleblowing:
The “treasure trove of inside information” that Birkenfeld provided U.S. officials formed “the foundation for the UBS debacle and everything that followed.” Indeed, thanks to one of “the biggest whistleblowers of all time,” the U.S. government (take a deep breath) received: $780 million and the names of 250 high-dollar Americans with secret accounts . . . another 4,450 names and accounts of U.S. citizens provided as part of a joint settlement between the U.S. and Swiss governments; more than 120 criminal indictments. . . the closure of prominent Swiss banks—including the oldest private bank . . . more than $5.5 billion collected from the IRS Offshore Voluntary Disclosure Program (OVDP), with untold tens of billions of dollars still payable due to only a quarter of the 39,000 OVDP cases being closed . . . “
In another successful precedent setting tax whistleblower case, anonymous whistleblowers, identified only as Whistleblower 21276-13W and Whistleblower 21277-13W, obtained a reward of $17,791,607.00 in the first tax whistleblower case ruling that tax whistleblowers were entitled to collect rewards based on criminal fines and penalties obtained by the Department of Justice. This landmark decision was cited to by Congress in amending the IRS tax law to ensure that criminal penalties were explicitly included in the IRS whistleblower law.
In another record-breaking achievement, in 2018 Kohn, Kohn and Colapinto’s tax whistleblowers obtained over $158 million in awards, the most compensation for whistleblowers ever obtained in a single year by any firm under the IRS tax whistleblower law.
How the Danske Bank money-laundering scheme involving $230 billion unraveled
A 60 minutes interview with whistleblower client Howard Wilkinson
Banking: A Crack In the Swiss Vault
A 60 minutes interview with whistleblower client Bradley Birkenfeld
Frequently Asked Questions
Yes. Whistleblowers who live outside the U.S. can (and have) qualified for hundreds of millions of dollars in rewards. If you reside abroad, you should obtain an experienced whistleblower attorney to ensure that you can qualify for a reward.
No, but the IRS has very strict rules that in practice will protect the identity of the whistleblower. In order to file a tax whistleblower case the whistleblower must sign, under oath, a “Form 211.” Once filed, the IRS internal rules require that the IRS maintain the confidentiality of the whistleblower to the fullest extent permitted under law.
The law not only covers civil or criminal tax evasion, but also tax underpayments. The law also covers numerous bank-related activities, such as money laundering and the creation of undeclared foreign bank accounts. An experienced tax whistleblower lawyer can help you understand the full scope of this very broad law and properly file a claim.
The Internal Revenue Act has a highly effective tax whistleblower law that permits tax whistleblowers to obtain between 15-30% of any collected proceeds obtained by the government as a result of the original information filed by the whistleblower.