Atty. Jason Brent Freeman

Mr. Freeman is the founding member of Freeman Law, PLLC. He is a dual-credentialed attorney-CPA, author, law professor, and trial attorney. Mr. Freeman has been named by Chambers & Partners as among the leading tax and litigation attorneys in the United States and to U.S. News and World Report’s Best Lawyers in America list. He is a former recipient of the American Bar Association’s “On the Rise – Top 40 Young Lawyers” in America award. Mr. Freeman was named the “Leading Tax Controversy Litigation Attorney of the Year” for the State of Texas for 2019 and 2020 by AI. Mr. Freeman has been recognized multiple times by D Magazine , a D Magazine Partner service, as one of the Best Lawyers in Dallas, and as a Super Lawyer by Super Lawyers, a Thomson Reuters service. He has previously been recognized by Super Lawyers as a Top 100 Up-And-Coming Attorney in Texas Mr. Freeman currently serves as the chairman of the Texas Society of CPAs (TXCPA). He is a former chairman of the Dallas Society of CPAs (TXCPA-Dallas). Mr. Freeman also served multiple terms as the President of the North Texas chapter of the American Academy of Attorney-CPAs. He has been previously recognized as the Young CPA of the Year in the State of Texas (an award given to only one CPA in the state of Texas under 40). Mr. Freeman serves on the law school faculty at SMU's Dedman School of Law, where he has taught a course in the law of federal income taxation for nearly a decade, and he is a frequent public speaker across the country, presenting and educating on various legal topics. He is also a Forbes contributor for tax and white-collar legal matters. Mr. Freeman represents clients in litigation and disputes, with a particular focus on federal and state tax controversies, as well as white-collar and financial disputes, both civil and criminal. He handles IRS audits and other investigations and represents clients facing tax and white-collar or financial-related charges. He also advises and assists clients with tax and regulatory compliance, including domestic and international tax planning and regulatory reporting requirements, as well as cryptocurrency and Blockchain matters. Mr. Freeman serves as trial counsel in complex business and commercial disputes, trying cases to juries and to the bench. He is experienced in civil cases involving an array of disputes, including fraud, breach of fiduciary duty, civil RICO, executor and trustee litigation, complex probate litigation, negligence, trade secrets, partnership disputes, breach of contract, and other matters. Mr. Freeman frequently serves as an expert witness. He also represents professionals—including attorneys and CPAs—before regulatory boards and in disciplinary hearings. Leveraging his CPA background, Mr. Freeman often represents clients in complex financial and regulatory matters that involve sophisticated forensic accounting analyses. He has handled hundreds of IRS audits and other investigations and has represented clients facing a broad array of tax and white-collar or financial-related charges, including tax evasion, bank fraud, money laundering, Bank Secrecy Act violations, securities fraud, computer intrusion and Medicare fraud, as well as clients in disputes with the Securities & Exchange Commission (SEC). He also represents clients in asset forfeiture cases. Mr. Freeman's litigation experience includes serving as trial counsel in a criminal tax evasion and conspiracy jury trial in the Federal District Court for the United States Virgin Islands. In addition, Mr. Freeman represents clients in appellate matters, serving as lead appellate counsel, presenting oral argument in a case before the United States Court of Appeals for the Third Circuit. Profiles of Jason • TXCPA's Chairman, Jason Freeman • Attorney At Law Magazine, Attorney of the Month Jason Freeman Examples of Jason’s Briefing • Civil Rico Complaint • Original Complaint Against the IRS • Opposition to DOJ’s Motion to Dismiss • Sur-Reply Regarding Subject Matter Jurisdiction • Motion to Dismiss Indictment • Motion to Dismiss Federal Election Code PAC Indictment • Appellate Brief—Administrative Procedures Act (APA) • Cryptocurrency/Bitcoin Fraud Complaint Examples of Litigation Depositions • Fact Witness Fraud Deposition (Szeto) • Expert Deposition (Hastings) • Fact Witness Conspiracy Deposition (Cole) • Fact Witness Impeachment Deposition (Denegre) • Fact Witness Int’l Asset Tracing Deposition (Adema) 2019 Representative Cases • Civil Lawsuits Served as lead counsel and obtained multi-million-dollar recovery for multiple clients in lawsuits against multinational Fortune 50 company. • Tax Litigation; Wrongful Seizure Recovered hundreds of thousands of dollars as lead counsel in suit against United States/IRS and Department of Justice for wrongful collection activities and seizure of assets. • Criminal Tax Investigation; Non-Prosecution Represented client in criminal tax referral involving allegations of income tax evasion; “killed case,” obtaining declination to prosecute client from United States Attorneys Office. • Criminal Tax Investigation; Non-Prosecution Represented client in criminal tax investigation by IRS Criminal Investigation Division involving allegations of income tax evasion; “killed investigation,” obtaining agreement from IRS CID not to seek prosecution against client. • Criminal Investigation; Seizure; Non-Prosecution Represented client under federal investigation for laundering and facilitating cryptocurrency exchanges following government seizure of cash. “Killed case,” and obtained government declination to pursue criminal charges, as well as obtained return of all seized funds. • State Criminal Tax Investigation; Non-Prosecution Represented client in state criminal tax investigation and obtained dismissal of charges. • Civil Lawsuit Won lawsuit involving shareholder dispute and claims of embezzlement involving seven-figure damages. • Civil Litigation Represented company and recovered hundreds of thousands of dollars on behalf of client from former embezzlement. • Criminal Tax Investigation; Non-Prosecution Represented client in federal criminal investigation related to alleged healthcare fraud and false statements, and obtained non-prosecution. • White-Collar Government Litigation Represented clients in litigation with Department of Justice regarding Federal Communications Commission (“FCC”) monetary penalty; obtained removal of judgment against individual client and 97% reduction of penalty for remaining clients. • Tax Planning Drafted Private Letter Ruling to obtain IRS consent to tax treatment. • Tax Litigation; U.S. Virgin Islands Represented client in Tax Court litigation, challenging IRS proposed assessment denying United States Virgin Islands (USVI) bona fide resident status and tax benefits; obtained concession from IRS and full tax benefits. Other Representative Cases • White-Collar Criminal Defense Lead criminal defense counsel for client indicted for allegedly hacking Microsoft and EA Sports company servers and illegally obtaining more than $20 million of virtual currency laundered through Russian and Chinese secondary markets. Obtained resolution of no prison time for client. • White-Collar Criminal Defense; Parallel Proceedings Represented client in multiple, parallel federal proceedings, including federal criminal proceedings and indictment for bankruptcy fraud and money laundering; SEC securities fraud proceedings; and federal civil action for alleged $200 million fraud. Obtained dismissal from federal suit alleging $200 million damages and release of client from prison. • IRS High-Wealth Audits; Puerto Rico Represented client in IRS “wealth squad” (Global High Wealth Industry Group) audit involving Puerto Rico Act 20/22 benefits; obtained “no-change” audit. • IRS Tax Representation; Puerto Rico Represented client in challenging IRS assessment denying Puerto Rico Act 20/22 benefits; obtained reversal and removal of full assessment. • Tax Litigation Represented clients in proceedings to quash international tax Formal Document Requests, seeking documentation regarding foreign accounts. • White-Collar Criminal Defense Represented client in federal criminal charges involving alleged mail and wire fraud, money laundering, and false statements related to Federal Election Code and political action committees. • White-Collar Criminal Defense; Non-Prosecution Represented client in grand jury investigation with respect to allegations of perjury, obstruction of justice, and financial kickback scheme, obtaining United States Attorneys Office’s agreement not to prosecute. • White-Collar Criminal Defense Represented client accused of bank fraud involving in excess of $50 million. • Criminal Tax Defense Represented client as criminal counsel in federal criminal case in United States Virgin Islands involving allegations of criminal tax evasion and conspiracy. • Appellate Served as lead appellate counsel in federal court of appeals (Third Circuit Court of Appeals, St. Croix, USVI), providing oral argument in federal tax case. • Government Penalty Representations Obtained complete removal of substantial Affordable Care Act (“ACA”) Employer mandate penalties. • State Tax Litigation Represented company as lead counsel in Texas state franchise tax dispute involving assessments of more than $1.5 million and assertion of Texas sourcing based on location of computer servers and electronic storage. Obtained complete removal of franchise tax assessment. • Federal Criminal Defense Following appointment as counsel, initiated investigation and obtained release of client from prison after uncovering wrongful investigative actions and entrapment. • IRS “SEP” Audit/Investigations Represented client in Special Enforcement Program (“SEP”) audit/investigation involving millions of dollars of alleged unreported income and several million dollars of unpaid tax and assessments; obtained deal to avoid criminal referral and avoidance of fraud penalties. • IRS International Penalty Defense and Voluntary Disclosure Represented client in IRS offshore voluntary disclosure, guiding client through an “opt out” and reducing penalties by hundreds of thousands of dollars through penalty defense. • Criminal Tax Defense Represented client against criminal tax evasion charges involving allegations of the evasion of tax in excess of $1.5 million. Obtained result of no prison time. • IRS Tax Penalty Representation Obtained penalty abatement and removal of IRS penalties in excess of $14 million. • Federal Tax Litigation Represented client in Tax Court, obtaining complete removal of more than $300,000 in tax assessments. • Innocent Spouse Relief/Penalty Relief Obtained innocent spouse relief, removing liability for tax liabilities of more than $500,000. • Innocent Spouse Relief/Penalty Relief Obtained innocent spouse relief, removing liability for tax liabilities of more than $600,000. • Innocent Spouse Relief/Penalty Relief Obtained innocent spouse relief, removing liability for tax liabilities of more than $1,000,000. • Appellate Served as appellate counsel in Fifth Court of Appeals in case involving allegations of fraud among business owners. Obtained appellate victory. • Transactional Represented clients in international corporate reorganization, involving liquidation of foreign subsidiary and FIRPTA planning. • Transactional Represented client involving restructuring of international fund and corporate structure, as well as corporate dissolution. • IRS Represent client in IRS offer in compromise involving offer to compromise tax debt of more than $15 million for less than $100,000. • IRS Represented client in obtaining IRS offer in compromise, settling tax debt of more than $1 million dollars for less than $150,000. • IRS Voluntary Disclosure/Cryptocurrency Represent client in IRS voluntary disclosure involving multi-million-dollar cryptocurrency holdings. • Transactional/Cryptocurrency Represented client in international corporate structuring and blockchain-based cryptocurrency token development. • IRS Trust Fund Recovery Penalty Represented client against IRS assessment of Trust Fund Recovery Penalty. Obtained complete removal of Trust Fund Recovery Penalty. • Cryptocurrency Tax Represented client with significant cryptocurrency transactions, reducing reported taxable transactions from cryptocurrency events by more than $1 million. • Domestic Transactional Advised client regarding corporate transaction involving complex partnership tax reporting and liquidation. • Tax Opinions Tax planning and opinion regarding capital gains treatment in complex transaction, resulting in tax savings. • International Tax Advised Hong Kong entity regarding reorganization and federal tax compliance obligations and planning. • International Transactional Served as counsel and advised client regarding multi-million-dollar international asset purchase agreement. • International Transactional Served as counsel and advised client regarding multi-national corporate manufacturing and business structure, including guiding client with respect to international tax compliance. Honors & Awards • Recognized by The Best Lawyers in America©, U.S. News & World Report and Best Lawyers® • Leading Tax Controversy Attorney of the Year, Texas, Acquisition International • Super Lawyers, 2020 (Super Lawyers is a Thomson Reuters service) • The American Bar Association's “On the Rise – Top 40 Young Lawyers” in American Award • Best Lawyers Under 40 in Dallas, D Magazine, 2018 • Best Lawyers in Dallas, D Magazine, 2018 Tax Litigation • Best Lawyers in Dallas, D Magazine, 2017 White-Collar Defense (As published by D Magazine, a D Magazine Partners service) • Best Lawyers in Dallas, D Magazine, 2016 Tax (As published by D Magazine, a D Magazine Partners service) • Best Lawyers in Dallas, D Magazine, 2015 Tax (As published by D Magazine, a D Magazine Partners service) • Super Lawyers Rising Stars 2017, Tax Law, Super Lawyers Magazine (Super Lawyers is a Thomson Reuters service) • Super Lawyers Rising Stars 2016, Tax Law, Super Lawyers Magazine (Super Lawyers is a Thomson Reuters service) • Super Lawyers Rising Stars 2014, Tax Law, Super Lawyers Magazine (Super Lawyers is a Thomson Reuters service) • Young CPA of the Year Award, 2015, Texas Society of CPAs • Rising Star, 2014 Texas Society of CPAs • Committee Member of the Year, Dallas CPA Society, 2014 • Member Spotlight: AICPA's Tax Section Feature Member, Dec. 2014 • State Bar of Texas Tax Section Leadership Academy, 2014 • TSCPA "A Day in the Life" Feature Member, Jan. 2015 • Member of Leadership Dallas Class of 2019 • Leading Tax Controversy Litigation Attorney of the Year, Texas by Leadings Advisors • Selected to America's Top 100 Criminal Defense Attorneys • Leading Tax Controversy Attorney of the Year 2020, Texas, Acquisition International. • Best Lawyers in Dallas, D Magazine, 2019 Tax (As published by D Magazine, a D Magazine Partners service) • Super Lawyers, 2019 (Super Lawyers is a Thomson Reuters service) • The American Bar Association's “On the Rise – Top 40 Young Lawyers” in American Award Publications • IRS Intends To Audit More High-Wealth Taxpayers - June 21, 2020 • Everything PPP Borrowers Need To Know About Why The SBA's 75% Rule Is Wrong - May 22, 2020 • SBA Issues PPP Loan Forgiveness Guidance, A Few New Rules: What You Need To Know Now - May 17, 2020 • PPP Borrowers And False Certifications: SBA Extends Amnesty Under Safe harbor - May 6, 2020 • Congressional Leaders Tell Treasury That PPP Borrowers Should Be Entitled To Deductions - May 6, 2020 • Should Employers Get A Tax Opinion For Paid Sick Leave Credits? - May 2, 2020 • U.S. Government Continues To Crack Down On Unreported Offshore Bank Accounts - April 30, 2020 • PPP Lawsuits Allege Banks Favored Larger Customers, A Second Round OF Funding Likely - April 23, 2020 • Ready. Set. GO. Small Businesses And The Race For Round 2 PPP Funds - April 22, 2020 • Why The SBA's New Self - Employed PPP Guidance Got IT Wrong - April 16, 2020 • Self-Employed And Need A PPP Loan? The SBA Just Issued New Guidance For You - April 15, 2020 • Reviving An Economy And A Sense OF Hope: A Post-COVID-19 World - April 12, 2020 • The World 2.0: Is Coronavirus The Great Disrupter? - April 11, 2020 • PPP Loan: Do Private Equity And Venture Capital Backed Companies Qualify? - April 10, 2020 • Five Things Every Paycheck Protection Program Borrower Should Do After Receiving A Loan - April 9, 2020 • Flattening The Economic Curve: The High Points Of Coronavirus Tax Relief - April 5, 2020 • Choice of Entity After Tax Reform, Today's CPA Magazine, March 2018 • Tax Reform is Here: A Brief Primer on the Key Business Provisions, Today's CPA Magazine, May 2018 • Bitcoin, Blockchain, and the Revolution to Come, Today's CPA Magazine, January 2018 • A Primer on the Tax Implications of Settlements and Judgments, Dallas Bar Association Headnotes, December 2017 • Held Captive: Micro-Captive Insurance in the Aftermath of Avrahami, Today's CPA Magazine, November 2017 • IRS Penalties – A Brief Primer, Today's CPA Magazine, September 2017 • Employment Tax Enforcement Rising to a Top Priority, The Journal of Accountancy, July 2017 • Employment Tax Enforcement is Trending, The Tax Advisor, AICPA, July 2017 • Representing Taxpayers in Sensitive Audits: A Look at the Fundamental Challenges of an Eggshell Audit, Today's CPA Magazine, July 2017 • Partnership Tax Audits: The New Rules, AICPA Tax Section Publication, May 2017 • Why (Nearly) Every Partnership Agreement Should be Amended, Today's CPA, May 2017 • Foreign-Owned Domestic Disregarded Entities: The New Reporting Requirements, The Tax Advisor, AICPA, April 2017 • An Update on International Tax Enforcement, Today's CPA, March 2017 • Tax Reform Under a Trump Administration, Today's CPA, January 2017 • Employment Tax Enforcement is on the Rise, Today's CPA, November 2016 • A Glimpse into the New Partnership Audit Rules, AICPA, The Tax Advisor, October 2016 • Bitcoin and Beyond: The Reality of Taxing and Regulating Virtual Currency, Today's CPA, September 2016 • A Brave New World: The Panama Papers and the United States Role as a Tax Haven, Today's CPA, June 2016 • Electing out of the BBA Partnership Rules, AICPA Tax Section, June 2016 • Internet Tax Freedom: State Taxation and the Internet, Today's CPA, May 2016 • The Evolution of Partnerships and Partnership Audits, Today's CPA, March 2016 • The IRS Budget: Taking Stock, Today's CPA, Janu