IRS Criminal Priorities and Hot Topics for Criminal Prosecution

Michele Leichtman Weiss is a Principal at Holtz, Slavett & Drabkin. She has over 20 years of experience in tax controversy and litigation matters. Michele helps her clients resolve their civil and criminal tax matters. She represents her clients in all aspects of tax controversy, in examinations, appeals and collection matters, at the administrative level and in litigation with federal, state and local tax authorities including the IRS, FTB, California Department of Tax and Fee Administration (CDTFA), EDD, Board of Equalization, Office of Tax Appeals (OTA), the County Assessor and LA City Finance Office. Michele has expertise in many substantive and procedural tax issues including tax penalty abatement, conservation easement deductions, offshore disclosure matters, employment tax matters, sales tax audits, research and development credits, collection due process and non-profit matters. Michele handles property tax matters in all California counties including special assessments, escape assessments, change in ownership issues and property tax appeal representation.

Wilfred brings 22 years of global federal law enforcement experience from the U.S. Department of Treasury, plus, leadership in fraud detection at one of the nation’s largest publicly owned commercial banks, City National Bank, a subsidiary of the Royal Bank of Canada. His diverse experience clearly differentiates him in the banking industry in the U.S. and abroad. 

Throughout his career with IRS Criminal Investigation, Wilfred demonstrated excellence in his roles conducting and supervising investigations involving tax fraud, investment fraud, bank and mortgage fraud, recycling fraud, public corruption, identity theft, cyber fraud, anti terrorist financing, domestic and international money laundering (involving Anti Money Laundering and Bank Secrecy Act violations), narcotics, and white-collar related money laundering. These cases used the International Emergency Economic Powers Act (IEEPA), included placing of individuals on the Office of Foreign Asset Control (OFAC) list, and prosecuting individuals using the RICO (Racketeer Influenced and Corrupt Organizations Act) statute. As a Supervisory Special Agent, Wilfred managed a group consisting of up to 12 agents and two support staff. He was responsible for managing an inventory of 100 active investigations at a time encompassing a domestic and international scope. 

As a Senior Fraud Detection Investigator for City National Bank, Wilfred drew on his experience conducting investigations into fraudulent activities resulting in filing Suspicious Activity Reports (SAR). These investigations involved an extensive forensic accounting of financial transactions from all aspects of the bank’s line of products – including wire transfers, securities, Automated Clearing House (ACH) transfers, loans, deposits and checks. Wilfred worked with City National Bank’s Legal Department and the Bank Secrecy Act Groups to mitigate the risk posed by specific clients’ fraudulent activity.

Victor spent over 30 years in federal law enforcement with Internal Revenue Service Criminal Investigation. As the Chief, Criminal Investigation (CI) headquartered in Washington, D.C., among his duties, Victor oversaw a worldwide staff of 4,200 CI employees, whom investigate and assist in the prosecution of criminal tax, money laundering, and narcotics-related financial crimes. One of his responsibilities was to address offshore tax evasion. Some of his accomplishments included doubling the international cadre of special agents posted throughout the world. 

Victor worked extensively with international law enforcement throughout Europe and Asia and South America. Specifically, he was responsible for the Simultaneous Criminal Investigation Program (SCIP) Agreements with Korea, Japan, Spain, and other countries. He added agents to Europol as well as the OECD headquartered in Paris, France. He was responsible for the formation and intake of the Offshore Voluntary Disclosure Program to address the non disclosure of foreign financial accounts by U.S. citizens. 

Subsequently, Victor was the EVP Compliance and Consultant to the CEO for Samsung Electronics America. As the EVP Compliance for the North American Headquarters, his responsibilities included all areas of the Compliance Program for Canada, North America, and parts of Mexico.