You don't need to know it's fraud.
You just need to know it doesn't look right.

Most people who contact us don't arrive with a legal theory. They arrive with a feeling — something they've seen at work that doesn't add up, and a growing suspicion that it's deliberate. They're usually right. But they almost always underestimate the value of what they know.

This page is for people who aren't sure. If you recognise anything here, you probably have enough to start a conversation with us.

You might recognise these patterns

You don't need to understand the tax law behind them. You just need to have seen the paperwork.

Invoices between group companies that don't match any real service. Your subsidiary pays a "management fee" or "advisory fee" to another entity in the group — maybe in Luxembourg, the Netherlands, Ireland, or Singapore. The invoices arrive regularly. The amounts are large. But you can't point to anyone who actually provides the service being charged for. The fees seem to exist so that money leaves your entity and arrives somewhere the tax rate is lower.

Licensing payments for intellectual property held offshore. Your company pays royalties to a related entity for the right to use a brand, a patent, or a software licence. The entity that owns the IP has no employees, or very few. It doesn't develop anything. It exists to receive payments from operating companies in higher-tax jurisdictions. You see the invoices, the intercompany agreements, or the board minutes approving the arrangement.

Loans between related entities at rates no outside lender would accept. One entity in the group lends money to another at an interest rate that is either far above or far below market rates. The effect is to shift profit — either by inflating interest income in a low-tax jurisdiction or by creating deductible interest expense in a high-tax one. You see the loan agreements, the interest calculations, or the cash movements.

Revenue booked in the wrong country. Sales are made to US customers, or services are delivered in the United States, but the revenue appears in the accounts of an entity in a different country. The US entity is characterised as a "limited risk distributor" or a "commissionnaire" that earns a small margin, while the real profit flows to an entity with fewer people and lower taxes. You see the contracts, the commission calculations, or the customer correspondence that tells a different story from the accounts.

Costs allocated in ways that don't reflect reality. Your entity bears costs — for R&D, for infrastructure, for shared services — that benefit the whole group, but the recharges don't reflect who actually uses what. The effect is to concentrate deductible costs in high-tax jurisdictions and profits in low-tax ones. You see the cost allocation models, the transfer pricing documentation, or the spreadsheets where the numbers are adjusted.

Dual sets of figures. The numbers presented to tax authorities don't match the numbers used for internal reporting, management accounts, or board presentations. The differences aren't rounding — they're structural. Revenue, margins, or functional profiles are described differently depending on the audience.

Transactions that are unwound, restated, or reclassified near year-end. You see adjustments that change the character or destination of income — reclassifying trading income as a capital receipt, redirecting revenue to a different entity, or converting a sale into a licence. The timing and pattern suggest the adjustments are driven by tax outcomes rather than commercial reality.

You don't need all of this

One pattern is enough. You don't need to have seen the whole structure — you need to have seen a piece of it that doesn't make sense. We know what the rest of the structure usually looks like. We know what questions to ask. We know what documents the IRS will need and where they're likely to be. Your piece of the puzzle tells us where to point.

"But I only see invoices" / "I'm just in AP"

Accounts payable staff, management accountants, financial controllers, tax analysts, treasury staff, internal auditors, and executive assistants routinely see the documents that matter most: intercompany invoices, fee schedules, loan agreements, transfer pricing reports, board minutes, tax provision workpapers, and cash flow instructions. These are the documents that reveal the gap between what a company tells the tax authorities and what actually happens inside the business.

You don't need to be the CFO. You don't need to understand the tax strategy. You need to have seen documents that show money moving in ways that don't reflect the underlying economic activity. That's what the IRS cares about. And that's almost certainly what you're looking at.

"Is it big enough?"

The IRS mandatory award programme applies to cases where the tax in dispute exceeds $2 million. That sounds like a lot — but multinational transfer pricing cases routinely involve tens or hundreds of millions of dollars. If the company you work for is a multinational with significant US revenue, the threshold is almost certainly met. We can tell you in the first conversation.

If the amount is smaller, there is still a discretionary award programme that covers claims below the $2 million threshold. The awards are lower, but the process is real and the IRS does pay them.

"What if I'm wrong?"

Then nothing happens. The IRS doesn't pursue cases where the information doesn't support a claim. You are not penalised for reporting in good faith. There is no cost to you — through us, there is no fee unless there is a recovery. If what you've seen turns out to have a legitimate explanation, we'll tell you, and that's the end of it.

But in our experience, people who think something is wrong are almost always right. You work inside the business. You see the actual transactions. Your instinct that something doesn't add up is based on evidence you encounter every day — you just may not have the tax vocabulary to describe why it's wrong. That's our job, not yours.

What happens next

If anything on this page sounds familiar, read the security guide first. Then open a secure channel and describe what you've seen — in plain language, in your own words. Don't use legal terminology. Don't try to build a case. Just tell us what you see at work that doesn't look right.

We'll tell you whether it qualifies, what it could be worth, and exactly what to do next. Anonymously, at no cost, with no obligation.

This page was last updated on 14 February 2026.