Jay Nanavati was quoted in a Bloomberg Law article about a Big Law firm linked to a Justice Department probe of Puerto Rico Tax Shelters.
The law firm is involved in the investigation as a result of the IRS ramping up enforcement efforts on taxpayers claiming Puerto Rico corporate residency tax benefits under Act 20 and Act 22 (now technically known collectively as Act 60).
According to Bloomberg Law, the law firm was subpoenaed by the Miami U.S. Attorney’s Office and is complying with the government’s investigation of its clients’ records. The law firm has reportedly advised its clients who may be impacted by the investigation to consider seeking outside legal representation.
“I have several clients who have received these letters,” Jay told Bloomberg Law. “Some are complying with them, and some are choosing to fight turning over their privileged communications.”
The potential outcome of the investigation is unclear, but the subpoenas indicate that the IRS and DOJ remain focused on targeting those they believe may have improperly claimed tax incentives designed for Puerto Rican companies that export services to other jurisdictions.
You can learn more about the investigation by reading the complete article here.
About Jay
Jay is a criminal tax defense attorney and a fellow of both the American College of Trial Lawyers and the American College of Tax Counsel. He represents individuals and entities facing investigations and prosecutions by the IRS, the FBI, state investigative agencies, U.S. Attorney’s offices, and the Department of Justice Tax Division. Jay has defended clients against federal investigations and charges throughout the country, and he has substantial experience representing clients accused of promoting or participating in so-called tax shelters, including captive insurance programs, conservation easements, and Puerto Rico’s Act 20/Act 22 program. In many instances, Jay represents tax professionals facing such accusations.
