Joseph A. Rillotta

Partner

(202) 742-8417

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Joseph Rillotta assists clients at all stages of government investigations, with a particular emphasis on tax controversies. He has significant experience in both prosecution and defense, having worked as a trial attorney with the U.S. Department of Justice (DOJ) Tax Division and as counsel to individuals and entities in financial crimes and investigations and related litigation. He joins the firm from the Department of the Treasury, where he has served as counselor to two IRS Commissioners.

Mr. Rillotta represents clients in white collar criminal defense matters. He counsels corporate officers, executives, professionals, and small business owners in Internal Revenue Service, grand jury, and state revenue authority investigations. He defends clients facing allegations of public corruption and procurement fraud, monetary crimes and regulatory violations, and violations of the Foreign Corrupt Practices Act (FCPA). Mr. Rillotta also counsels corporate clients with respect to internal investigations, proactive compliance assessments, and remediation.

Mr. Rillotta represents clients in civil litigation in the U.S. Tax Court and other federal and state courts across the country. He contests IRS assessments of tax and imposition of penalties, defends nonprofit organizations when their tax-exempt status is jeopardized, and defends clients in Fasle Claims Act litigation and investigations.

Prior to joining the firm, in his capacity as counselor to the IRS Commissioner, Mr. Rillotta advised the Commissioner and IRS Chief Counsel on allegations of misconduct by IRS personnel and oversaw agency responses to congressional and Inspector General inquiries. Mr. Rillotta also spent six years in the Tax Division of the DOJ, where he prosecuted tax and financial crimes in large-scale grand jury investigations, jury trials, bench trials, and appellate proceedings.

Mr. Rillotta was admitted to practice in Maryland in 2003 and Washington, D.C. in 2005.

Harvard Law School, J.D., Cum Laude, 2003
Harvard College, A.B. in Government, Magna Cum Laude, 1999

Bar of the District of Columbia
State Bar of Maryland
American Bar Association
- Member, Litigation Section
- Member, Tax Section, Civil and Criminal Penalties Committee
- Chair, Tax Section, Subcommittee on Monetary Violations and Forfeitures (2019-2023)

Bar Association of the District of Columbia, 2005
State Bar of Maryland, 2003
United States Tax Court
United States Court of Appeals, Fourth Circuit
United States Court of Appeals, Fifth Circuit
United States Court of Appeals, Ninth Circuit
United States District Court - District of Columbia
United States District Court - Maryland
United States District Court - Middle District of North Carolina
United States District Court - Southern District of New York
United States District Court - Western District of Oklahoma

Legal 500 for Dispute Resolution: Corporate Investigations and White-Collar Criminal Defense, 2022
Legal 500 for Tax: U.S. Taxes: Contentious, 2022
Washington, D.C. Super Lawyers, Washington, D.C. Super Lawyers® for Criminal Defense, 2022-2023
Tax Division Awards for Outstanding Achievement, 2010-2011
D.C. Bar Capital Pro Bono High Honor Roll, 2020

"Publix Heiress Tax Case Signals Continued IRS Supervisory Issues," Bloomberg Tax, November 13, 2025
"Sidelining IRS's Criminal Tax Counsel Would Harm Taxpayers," Bloomberg Tax, November 4, 2025
"The People vs. ChatGPT?: Can an AI Program Commit a Fraud? Can It Get its Human Overseers in Trouble?" Los Angeles Daily Journal, March 14, 2023
"In Second CTA Rulemaking, FinCEN Outlines Access to Beneficial Ownership Database," January 10, 2023
"A New Species of Enforcement?: State Attorneys General Are Increasingly Involved in Tax Enforcement," Tax Notes, October 20, 2022
"International Tax Enforcers Flex Their Muscles in Puerto Rico," Bloomberg Law, August 15, 2022
"Practitioners Note the Corporate Transparency Act's Potential, But Caution 'Wait and See' on Final Rules," May 23, 2022
"Regulators Issue Guidance on U.S. Banks' Reporting Obligations Regarding Suspected Foreign Corrupt Practices," September 16, 2020
"U.S. Supreme Court Extends Statute of Limitations for Privately Initiated False Claims Act Lawsuits," National Law Review, May 13, 2019
"U.S. Supreme Court Hears Oral Argument in Cochise Consultanc, Seems Poised to Effectively Extend Statute of Limitations for Privately Initiated False Claims Act Lawsuits," National Law Review, April 3, 2019
"DOJ May Grant Declinations to Companies that Voluntarily Self-Disclose FCPA Violations by Senior Executives," National Law Review, March 4, 2019
"DOJ Clarifies Application of FCPA Corporate Enforcement Policy to Resks Discovered During the M&A Process," August 14, 2018
"The Department of Justice Announces Expansion of Self-Disclosure-Based Leniency Principles to All Corporate Cases," National Law Review, March 4, 2018
"Marinello Looming, District Court Dismisses Omnibus Clause Count," Tax Notes, November 27, 2017
"Unclaimed Deductions at Criminal Tax Sentencing," Tax Notes, July 10, 2017
"New York Banks Face New Anti-Money Laundering Compliance Requirements, Effective January 1," National Law Review, December 6, 2016
"Beyond the SAR-C: Best Practices for Gaming Companies to 'Know Their Customer' and Avoid Organizational Money Laundering Liability in the Post-Sands Climate," UNLV Gaming Law Journal, September 1, 2014
"The DOJ Tax Division's Swiss Bank Program and Broader Trends in Offshore Banking Enforcement," Journal of Tax Practice and Procedure, June 1, 2014
"New Sentencing Guidelines Provisions May Significantly Impact Criminal Tax Cases," Journal of Tax Practice and Procedure, June 1, 2014

March 30, 2026

Texas Court Vacates FinCEN Beneficial Ownership Reporting Rule for Non-Financed Real Estate Transactions... [ read ]

Joseph Rillotta examines recent developments concerning the Treasury Department's efforts to collect beneficial ownership information, including the U.S. District Court for the Eastern District of Texas vacating FinCEN's 2024 rule on non-financed residential real estate transactions.

January 5, 2026

Memo to IRS-CI: Don't Forget to Tout Your Legal-Source Income Casework!... [ read ]

Joseph A. Rillotta takes a closer look at IRS Criminal Investigation's recently released "Top 10 Cases of 2025" and highlights the absence of any legal-source income tax evasion cases.

December 8, 2025

NCAA Transparency Advocate Accuses UCLA of Skirting IRS Rules on Tax Exemptions, NIL Payments... [ read ]

Joseph A. Rillotta examines allegations that UCLA used a tax-exempt charity to route NIL payments to football players, potentially circumventing rules on charitable deductions and giving the program an edge with NIL.