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The Tax Man Cometh

By Peter F.G. Schuur, Bruce E. Yannett, Steven S. Michaels and John T. Pierpont

The fact that FCPA violations carry the risk of significant U.S. tax law consequences is important throughout the year. Indeed, the tax consequence of FCPA violations is an issue U.S. law enforcement personnel are highlighting, as indicated by case filings and appearances by representatives of the Internal Revenue Service (IRS) at FCPA conferences. (At the January 2012 “FCPA Boot Camp” hosted by the American Conference Institute in Houston, Clarissa M. Balmaseda, a Special Agent in Charge of IRS Criminal Investigation in the Northern District of California, signaled the IRS's newfound willingness to step into the FCPA arena. American Conference Institute, “FCPA Boot Camp” at 4 (Jan. 2012) (on file with author). Another IRS representative, Debra Meyer, a Senior Agent in International Operations in the District of Oregon, spoke on the IRS' role in FCPA enforcement at the American Conference Institute's FCPA conference for the pharmaceutical, medical device and life sciences industry in May 2012. See American Conference Institute, “FCPA & Anti-Corruption for the Life Sciences” (May 2012) (on file with author).)

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