James N. Mastracchio

Jim Mastracchio is a seasoned advocate who chairs Dentons’ US Tax Controversy practice and Criminal Tax practice.

Jim’s work focuses on advising clients facing civil and criminal tax investigations. His work in civil tax disputes includes a wide range of civil tax reporting issues and the defense of structured products, tax-driven structures and their promotion. In the criminal tax arena, Jim represents clients facing tax fraud and evasion, conspiracy, obstruction, mail/wire fraud and monetary structuring charges.

Jim has represented regulated financial institutions within and outside the US on a variety of civil and criminal tax investigations. He served as an independent examiner for a major Swiss banking institution, advised foreign financial institutions on the implementation of Foreign Account Tax Compliance Act (FATCA) and Organization for Economic Cooperation and Development (OECD) reporting standards, and is currently lead counsel to a foreign financial institution facing criminal prosecution for its involvement with US account holders.

Jim has also represented more than 350 individuals located across the globe who have participated in the Internal Revenue Service's (IRS) Offshore Voluntary Disclosure Programs to resolve disputes involving previously undisclosed offshore accounts and structures. He regularly practices before the IRS (including the IRS Office of Appeals and IRS Criminal Investigation), the Department of Justice's Tax Division and various US attorneys' offices across the country, as well as in federal court.

Jim has been recognized as a leading national tax controversy lawyer in the US Legal 500 Litigation Guide and Super Lawyers. He is the author of the chapter "Best Practices for Managing Tax Investigations" in Inside the Minds: Common Issues in White Collar Law, published by Thomson West Publishing (2007). He has been widely quoted in the national media, including by The New York Times, The Wall Street Journal, The Washington Post, MarketWatch, Bloomberg BNA, TaxAnalysts, CCH and numerous other business and tax publications. Jim is a frequent speaker and panelist on civil and criminal tax matters.

Good to know

Job Types Partner
Areas of Practice 1) Tax Litigation and Dispute Resolution, 2) White Collar and Government Investigations, 3) International Taxation, 4) Banking and Finance and 5) Corporate Governance
Law School New York University, School of Law ( LLM,1996);New York University, School of Law (J.D.,1996)
Education tate University of New York at Albany (M.S.,1991)
Bar Member / Association District of Columbia State Bar Associations,California State Bar Associations
Most recent firm Dentons
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