A standard tax audit by the Revenue Service is a business challenge; a criminal investigation by the Investigation Service of the Ministry of Finance of Georgia is a threat to your freedom. The moment an investigation shifts from a civil dispute about how much tax is owed to a criminal inquiry into how it was paid, the stakes become infinitely higher. These are complex, document-intensive cases that require a rare and specialized blend of sophisticated tax law knowledge and aggressive criminal defense tactics. Our firm is one of the few in Georgia built to operate at this precise intersection, providing a robust and intelligent defense for businesses and individuals facing the full force of a state tax crime investigation.
The cornerstone of the government’s case in a tax evasion prosecution is proving willful intent. An honest mistake, a misunderstanding of Georgia’s complex tax code, or a good-faith reliance on the advice of an accountant is not a crime. The state must prove, beyond a reasonable doubt, that you deliberately and knowingly acted to conceal income or fraudulently reduce your tax liability. Our defense is laser-focused on dismantling this element of intent. We meticulously reconstruct your financial history and decision-making process to demonstrate a pattern of compliance or to show that any errors were unintentional, thereby transforming the narrative from one of criminal fraud to one of a legitimate civil tax dispute.
When the Investigation Service launches a probe, its actions are swift and aggressive. This can include surprise searches of your office, the seizure of critical servers and financial records, and the interrogation of your employees. Our crisis response is equally swift. We provide immediate, on-site legal counsel during searches to protect privileged documents and ensure the investigators do not exceed their authority. We take control of all communications, prepare all key personnel for interviews, and create a legal shield around your business to minimize disruption and protect your constitutional rights throughout the entire investigative process.
A purely legal defense is insufficient in a tax crime case. The battle is fought with numbers, and therefore, it must be won with superior financial analysis. Our firm employs a powerful two-track defense methodology. While our criminal lawyers manage the legal track—challenging warrants, filing motions, and protecting your rights—we simultaneously launch a financial track. We engage elite independent forensic accountants to conduct a parallel audit, building our own set of calculations and financial reports. This independent analysis is our most powerful tool, allowing us to expose errors in the government’s assessment and provide the factual evidence needed to undermine their entire case.
Our ultimate strategic goal in most tax crime cases is to "re-civilize" the dispute. We use the evidence from our parallel investigation and our deep knowledge of tax law to engage in high-level negotiations with prosecutors and the Investigation Service. We work to persuade them that the matter is a complex tax disagreement that should be resolved civilly with the Revenue Service, not criminally in a courtroom. By demonstrating the flaws in their criminal case, we can often negotiate a global resolution that settles the tax liability and secures a termination of the criminal investigation, protecting our client from the devastating consequences of an indictment.
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