Nathan J. Hochman, the former head of the US Department of Justice’s Tax Division, practices complex civil and criminal litigation, with a focus on white collar criminal defense, tax controversy, securities, and environmental matters. He represents individuals and organizations involved as targets, subjects, or witnesses in state and federal criminal investigations and related grand jury and pre-trial proceedings, conducts internal investigations, and handles complex civil litigation, arbitrations, trials, and appeals.
Over the past five years, Nathan has achieved notable successes representing clients throughout the world in connection with the US government’s ongoing efforts to investigate and prosecute US taxpayers, intermediaries (e.g., bankers, lawyers, accountants), and foreign banks for unreported offshore income and accounts. He has assisted scores of clients with unreported foreign bank accounts in successfully entering and completing the IRS Offshore Voluntary Disclosure Initiative program that commenced in 2009. That program offers taxpayers with such unreported offshore accounts lower civil penalties and the potential for criminal amnesty. He has additionally represented intermediaries who have facilitated alleged offshore tax evasion and have been targeted for criminal prosecution by the US Department of Justice’s Tax Division and US Attorney Offices. With respect to foreign banks and in connection with the Department of Justice’s amnesty program for Swiss Banks announced on Aug. 29, 2013, he has represented Swiss banks, acting as counsel and separately as an “independent examiner” of the Swiss bank’s compliance with the requirements of the program.
Articles in the National Law Review database by Nathan J. Hochman