Ian has more than 35 years of experience representing corporations and individuals in civil and criminal tax litigation, white-collar criminal defense, and complex corporate and commercial disputes, including:
- tax controversy work such as IRS administrative and grand jury investigations, Tax Court, Claims Court and District Court trials and appeals, jeopardy and termination assessments, responsible officer penalty and collection matters;
- corporate compliance matters involving the Bank Secrecy Act and USA PATRIOT Act and FATCA issues for financial institutions including banks, broker-dealers and mutual funds;
- commercial litigation focused on accounting and legal malpractice cases as well as securities and class action matters, all involving tax and related accounting issues; and
- corporate internal investigations for financial institutions and other entities, including claims under the Foreign Corrupt Practices Act.
Ian frequently advises individuals on their U.S. tax and foreign asset reporting (FBAR and FATCA) obligations and has represented hundreds of individuals with undisclosed foreign bank accounts through the IRS voluntary disclosure programs. He also counsels individuals and corporations in civil audits and criminal investigations arising out of tax-sheltered investments.