Allison Soares, a partner at Vanst Law LLP and an adjunct professor at San Diego State University, brings more than 15 years of tax controversy experience to criminal tax defense cases that most attorneys lack the technical foundation to handle effectively.
Introduction
Vanst Law LLP is a tax law and criminal tax defense firm with offices at 200 Spectrum Center Drive, Irvine, California, and 3170 Fourth Avenue, San Diego, California. Phone: 949-449-1446. Partner Allison Soares leads the criminal tax defense practice, bringing 15-plus years of specialization in tax controversies at the federal and state levels.
The firm represents clients facing IRS criminal investigations, California Franchise Tax Board enforcement actions, Employment Development Department matters, and California Department of Tax and Fee Administration enforcement. It also handles civil tax matters that carry criminal exposure, voluntary disclosure programs, and international compliance issues that can trigger criminal prosecution.
Practice Areas
IRS Criminal Investigations
An IRS criminal investigation is a serious matter that moves differently from a civil audit. Special agents gather evidence with the goal of prosecution. The firm represents clients during investigations, works to prevent charges from being filed, and defends those who have already been indicted. Attorney-client privilege protects communications with the firm in ways that communications with an accountant do not, making early attorney involvement essential.
Tax Fraud and Evasion Defense
Tax fraud and evasion charges at the federal level carry substantial prison sentences. The firm defends individuals and businesses facing these charges, drawing on Allison Soares’s deep technical knowledge of tax law to challenge the government’s factual and legal theories.
Employment Tax Fraud Defense
Employers who fail to withhold, deposit, or pay payroll taxes face both civil penalties and criminal prosecution. Employment tax fraud is a priority enforcement area for the IRS. The firm defends employers, business owners, and responsible parties facing these charges.
Sales Tax Evasion Defense
The California Department of Tax and Fee Administration pursues sales tax evasion cases aggressively. The firm represents clients facing CDTFA enforcement actions, from civil audits with criminal exposure to direct criminal referrals.
Voluntary Disclosure Programs
Taxpayers with unreported income or unfiled returns may be eligible for voluntary disclosure programs that can significantly reduce criminal exposure. The firm evaluates each situation and manages the disclosure process to achieve the best possible outcome.
International Tax Compliance
Foreign bank accounts, offshore assets, and international income that were not properly reported to the IRS can trigger criminal prosecution. The firm handles FBAR violations, FATCA compliance failures, and other international tax matters with criminal implications.
Willful Failure to File
Failing to file required tax returns can be prosecuted as a criminal offense when the failure is willful. The firm defends individuals charged with willful failure to file and works to establish defenses based on intent, knowledge, and the specific facts of each situation.
Audits with Criminal Implications
Some civil audits develop characteristics that suggest criminal referral is being considered. The firm monitors for these signals and intervenes proactively to protect clients when an audit appears to be moving in that direction.
Attorney Profile
Allison Soares is a partner at Vanst Law LLP with more than 15 years of specialization in tax controversies. She is an adjunct professor at San Diego State University, where her academic work reflects the same technical tax expertise she brings to criminal defense cases. She represents clients before the IRS, the California Franchise Tax Board, the Employment Development Department, and the California Department of Tax and Fee Administration. Her practice includes both civil tax matters with criminal exposure and direct criminal tax defense at the state and federal levels.
Location and Service Area
Vanst Law LLP operates from two California offices. The Irvine office is located at 200 Spectrum Center Drive. The San Diego office is located at 3170 Fourth Avenue. Phone: 949-449-1446. The firm serves clients throughout California in state and federal tax matters.
Client Focus
Clients who come to Vanst Law LLP for criminal tax defense are often already working with accountants or CPAs who have identified a problem. The critical distinction is that communications with an attorney are protected by attorney-client privilege, while communications with an accountant are generally not. When criminal exposure exists, the absence of that privilege protection can be devastating. Allison Soares provides confidential consultations that accountants legally cannot offer.
The firm’s combination of academic expertise and practical criminal tax defense experience is particularly valuable in cases involving complex technical tax questions, where the facts of the case intersect with disputed interpretations of tax law.
Frequently Asked Questions
Why does attorney-client privilege matter in a tax case?
Attorney-client privilege protects communications between a client and their attorney from disclosure to the government. Communications with an accountant or CPA do not carry this protection. In a criminal tax investigation, the government can subpoena accountants to testify about client communications. Working with an attorney from the beginning of any tax controversy with criminal potential protects those communications.
What is the difference between a civil tax audit and a criminal tax investigation?
A civil audit seeks to determine whether taxes owed were paid correctly. A criminal investigation seeks evidence to support a prosecution. The IRS Criminal Investigation Division uses special agents who are law enforcement officers. An audit can transform into a criminal referral when agents identify evidence of willfulness or fraud. The firm monitors civil audits for these signals.
What is a voluntary disclosure program and who is eligible?
Voluntary disclosure programs allow taxpayers to come forward about unreported income or unfiled returns in exchange for reduced criminal exposure. Eligibility criteria vary by program and timing. The firm evaluates each situation to determine whether voluntary disclosure is appropriate and manages the process to achieve the most favorable outcome.
Does the firm handle FTB and CDTFA matters in addition to IRS cases?
Yes. The firm represents clients in enforcement actions brought by the California Franchise Tax Board, the Employment Development Department, and the California Department of Tax and Fee Administration, in addition to IRS criminal investigations.
Closing
Criminal tax defense requires an attorney who understands both the law and the numbers. Allison Soares at Vanst Law LLP provides that combination, with 15-plus years of tax controversy experience, academic grounding in tax law, and a practice built around protecting clients when the IRS or California tax agencies turn from auditors into prosecutors. For confidential consultation, call 949-449-1446 or visit https://www.allisonsoares.com.