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Bryan C. Skarlatos

Bryan C. Skarlatos

Bryan C. Skarlatos

Partner

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New York City
T: 212.808.8100
F: 212.808.8108
[email protected]

For more than thirty years, Bryan C. Skarlatos has represented corporations and individuals in sensitive matters, many of which involve negotiation or litigation with government agencies. He has significant experience in federal and state tax audits, appeals and litigation, criminal tax investigations and white collar criminal prosecutions. Mr. Skarlatos also has an active practice providing tax and estate planning advice.

Mr. Skarlatos is an internationally recognized expert on reporting foreign assets to the Internal Revenue Service and has handled hundreds of voluntary disclosures, civil audits and criminal investigations involving alleged failure to report foreign assets. He also counsels corporations and individuals from around the world on how to come into compliance with U.S. tax law.

Mr. Skarlatos has been an adjunct professor at New York University School of Law for nearly twenty years where he teaches a class on Tax Penalties, Prosecutions and Procedures. He has developed an expertise in handling high stakes tax cases that could involve penalties or other sensitive issues. He is often retained by corporate taxpayers to evaluate the strength of tax positions for tax and financial reporting purpose and to advise on potential remedial actions, including corporate voluntary disclosures.

Mr. Skarlatos is also very experienced in tax whistleblower matters and represents both taxpayers accused of wrongdoing by whistleblowers as well as whistleblowers themselves in claims before federal and state tax authorities. Mr. Skarlatos testified before the Internal Revenue Service regarding the IRS whistleblower law and was retained by Senator Charles Grassley, the drafter of the IRS whistleblower law, to write an amicus brief on behalf of the Senator in the D.C. Circuit Court of Appeals.

Mr. Skarlatos is often retained as an expert in tax reporting standards and tax penalties by professionals, firms, and taxpayers accused of violating those standards. Mr. Skarlatos has been hired as an expert on criminal tax issues by a state prosecutor’s office and a foreign government. He has also testified before the U.S. House of Representatives Ways and Means Committee as an expert on tax penalties.

Mr. Skarlatos has been recognized by Super Lawyers as one of the Top 100 Lawyers in New York and in Best Lawyers in America where he was named “Lawyer of the Year” (Tax Litigation, New York) in 2014 and 2017.  He is also ranked Band One of Chambers USA: Americas Leading Lawyers for Business, which describes him as having a “smart reassuring presence with insight into the government…extremely knowledgeable and very well connected to the various tax authorities…Clients applaud him as being exceptionally brilliant at coming up with great outcomes.”

Dickinson School of Law of the Pennsylvania State University, J.D. (1985); cum laude; Woolsack Honor Society; Dickinson Law Review; Managing Editor, Dickinson Journal of International Law 

New York University School of Law, LL.M (1991) (Taxation)

S.D.N.Y., 1987

E.D.N.Y., 1987

N.D.N.Y., 1987

U.S. Tax Court, 1987

Third Cir. Court of Appeals, 1987

Court of Federal Claims, 1996

Second Cir. Court of Appeals, 1998

N.D. Texas, 2006

  • Mr. Skarlatos represents hundreds of taxpayers who are voluntarily disclosing to the IRS over $1 billion in off-shore bank accounts and related income tax liabilities.
  • Mr. Skarlatos represented three Swiss financial institutions that obtained Deferred Prosecution Agreements from the Department of Justice as part of the Swiss Bank Voluntary Disclosure Program.
  • Mr. Skarlatos represents many taxpayers who are being investigated by the Department of Justice for tax-related issues, including alleged failure to report foreign bank accounts and income earned on those accounts.
  • Mr. Skarlatos has represented several witnesses in regulatory investigations into trading practices at large financial institutions.
  • Mr. Skarlatos represented a large partnership in a withholding tax audit involving more than $50 million paid to foreign payees.
  • Mr. Skarlatos represented a professional firm in connection with a material advisor and promoter penalty audit.
  • Mr. Skarlatos has helped clients structure their affairs to avoid violating restrictions imposed by the Office of Foreign Assets Control.
  • Mr. Skarlatos has represented many individuals accused of money laundering and Bank Secrecy Act violations.
  • Mr. Skarlatos represents several whistleblowers who have reported to the IRS Whistleblower Office many billions of dollars in of unpaid income taxes.
  • Mr. Skarlatos represented a well-known businessman in a Tax Court case in which the IRS is claiming more than $130 million in taxes and penalties relating to alleged personal benefits from related-party transactions.
  • Mr. Skarlatos represents hundreds of taxpayers who are voluntarily disclosing to the IRS over $1 billion in off-shore bank accounts and related income tax liabilities.
  • Mr. Skarlatos represented three Swiss financial institutions that obtained Deferred Prosecution Agreements from the Department of Justice as part of the Swiss Bank Voluntary Disclosure Program.
  • Mr. Skarlatos represents many taxpayers who are being investigated by the Department of Justice for tax-related issues, including alleged failure to report foreign bank accounts and income earned on those accounts.
  • Mr. Skarlatos has represented several witnesses in regulatory investigations into trading practices at large financial institutions.
  • Mr. Skarlatos represented a large partnership in a withholding tax audit involving more than $50 million paid to foreign payees.
  • Mr. Skarlatos represented a professional firm in connection with a material advisor and promoter penalty audit.
  • Mr. Skarlatos has helped clients structure their affairs to avoid violating restrictions imposed by the Office of Foreign Assets Control.
  • Mr. Skarlatos has represented many individuals accused of money laundering and Bank Secrecy Act violations.
  • Mr. Skarlatos represents several whistleblowers who have reported to the IRS Whistleblower Office many billions of dollars in of unpaid income taxes.
  • Mr. Skarlatos represented a well-known businessman in a Tax Court case in which the IRS is claiming more than $130 million in taxes and penalties relating to alleged personal benefits from related-party transactions.
  • Mr. Skarlatos represents a number of taxpayers who are being criminally investigated by the Department of Justice for failure to report foreign bank accounts and income earned on those accounts.
  • Mr. Skarlatos represents several whistleblowers who have reported to the IRS Whistleblower Office more than $1 billion of unpaid income taxes.
  • Mr. Skarlatos represents a well-known businessman in a Tax Court case in which the IRS is claiming more than $100 million in taxes and penalties relating to alleged personal benefits from related-party transactions.
  • Mr. Skarlatos represents a famous politician from a foreign country who is indicted in the United States for allegedly depositing stolen money in a bank account in New York.
  • Mr. Skarlatos represents a hedge fund manager against whom the IRS is seeking to impose a multi-million-dollar tax fraud penalty.
  • Mr. Skarlatos was hired by a large private equity fund to represent one of its companies in connection with a federal tax dispute arising from the company’s cross-border business activities.
  • Mr. Skarlatos represents the owner of a construction company who is being investigated by the United States Attorney’s Office for the Eastern District of New York for criminal tax evasion.
  • Mr. Skarlatos helped a foreign investment fund avoid tens of millions of dollars of penalties relating to its failure to withhold taxes on payments to U.S. taxpayers.
  • Mr. Skarlatos convinced the United States Attorney’s Office to withdraw a filed indictment against a real estate developer who had not filed income tax returns for many years.
  • Mr. Skarlatos successfully resolved the audit of a wealthy investor who had donated a conservation easement on undeveloped land in upstate New York.
  • Mr. Skarlatos’ client, the owner of a large construction company, was cleared of all criminal and civil fraud charges relating to personal expenses charged to his business.
  • Mr. Skarlatos negotiated a favorable resolution of civil forfeiture charges arising from a client’s alleged money laundering activity.

Mr. Skarlatos created and co-chairs the annual New York University Tax Controversy Forum.  He also is co-chair of the Compliance Practice and Procedure Committee of the New York State Bar Association Tax Section and he is a former chair of the Civil and Criminal Tax Penalties Committee of the American Bar Association, the Personal Income Tax Committee of the New York City Bar Association and the Tax Committee of the New York County Lawyer’s Association.  Mr. Skarlatos is on the board of directors of the annual New York University Graduate Tax Institute, where he chairs a program on Ethics in Tax Practice, and he has been nominated to serve on several bar association task forces, including the New York State Bar Association task force on Attorney Client Privilege and the American Bar Association task forces on Tax Shelters, Circular 230, and Ethics 2000.

Mr. Skarlatos is on the Advisory Board of the Journal of Tax Practice and Procedure for which he writes a regular column on Tax Penalties and he is on the board of editors of the Practical Tax Lawyer.  He frequently speaks on topics related to civil and criminal tax controversies, including lectures for the IRS,  New York University Institute on Federal Taxation, the American Bar Association, the New York State Bar Association, the New York Country Lawyer’s Association, the Connecticut State Bar Association, the Tax Executives Institute, the Practicing Law Institute, the Bureau of National Affairs, the American Institute of Certified Public Accountants, and the New York State Society of Certified Public Accountants.  Mr. Skarlatos has written several articles for various law reviews and journals and he was co-author of a regular column in the New York Law Journal entitled, “Tax Litigation Issues.”

Bryan C. Skarlatos 2019 USA Chamber Award