
Investors who purchased “sovereign tribal tax credits” marketed by White River Energy Corp. paid real money for credits the IRS has confirmed do not exist. This is now under investigation by federal authorities, and some purchasers may face IRS penalties in addition to their investment losses. Financial advisors who recommended these credits may have failed to conduct adequate due diligence or disclose material risks before recommending them to clients.
(Email from IRS to Senate Committee on Finance, March 21, 2025, quoted in the U.S. Senate Finance Committee’s letter to Jay Puchir, Chairman and Chief Financial Officer, White River Energy Corp, March 21, 2025)
If you purchased White River Energy Native American Tax Credits and have suffered IRS rejection, penalties, or investment losses, contact Peiffer Wolf at 585-310-5140 or by filling out an online contact form for a FREE Consultation. It is imperative to seek legal advice promptly as legal deadlines may apply.
Beginning in late 2023, White River Energy Corp. (OTC: WTRV) — working with Nepsis Tax Advisors LLP and a network of financial advisers — sold what is described as “Native American Tax Credits” (NATCs), also marketed as “Sovereign Tribal Federal Tax Credits.” According to promotional materials and public reporting, the pitch was: pay 60 cents for every dollar of federal income tax credits, claim those credits on your federal return, and receive an implied 67% return on your cash. Buyers wired funds — with a minimum purchase of $100,000 — to accounts associated with Nepsis at U.S. Bank in Minneapolis and reportedly received documentation described as a “Tax Credit Certificate” to attach to their IRS filings.
The credits were represented as having been issued by a Native American tribe and registered with the U.S. Treasury. As of March 2024, White River publicly claimed to have registered $64 billion in credits. In reality, the U.S. Treasury confirmed to Bloomberg in December 2024 that no such credits exist. The IRS confirmed the same in writing to Congress in March 2025. Purchasers who claimed these credits on a tax return have had — or will have — that claim rejected by the IRS, and some taxpayers may face civil penalties of 20% or more of the amount improperly claimed.

November 2023
White River Energy Corp. announces a joint venture with Logistical Concepts involving an entity called White River Native CDFI, LLC. White River discloses the deal in an SEC filing, as reported by Sen. Wyden’s letter, claiming to have acquired $5.5 billion in federal income tax credits from a Native American tribe.
January 2024
White River identifies Nepsis Tax Advisors LLP as its distribution partner and begins working with a network of financial advisers and tax professionals to sell the credits to end buyers.
April 2024
White River obtains a legal opinion letter that it represents as supporting the legality of the credits and uses that letter to market the program as vetted.
May 2024
Program materials describe a minimum purchase threshold of $100,000 in credits ($60,000 cash) per transaction.
December 2024
Bloomberg publishes “Rich People Buy Tribal Tax Credits Treasury Says Don’t Exist,” reporting that U.S. Treasury officials said no such credits exist and that the Cherokee Nation had issued a cease-and-desist to White River. According to Senator Wyden’s letter to the SEC, White River reportedly held a conference call the same day with advisers. On that call, participants reportedly stated they had sold $5 million, $10–20 million, and $30 million in credits respectively — totaling at least $45–55 million.
March 2025
The IRS confirms in writing to the Senate Finance Committee that the credits “do not exist” and the IRS warns that taxpayers claiming the credits could face civil penalties. Nepsis reportedly informs clients it can no longer file the credits on their tax returns and allegedly refuses to refund purchase prices.
August 2025
The IRS updates its Internal Revenue Manual to formally classify tribal tax credits as a “scheme,” directing agents that such credits “are not allowed, regardless of the amount claimed or the type of documentation provided.”
January 2026
Senator Ron Wyden writes the SEC urging revocation of White River’s securities registration and confirms an active DOJ/IRS-CI criminal tax investigation of White River and Nepsis, with subpoenas issued and multiple subjects represented by counsel.
Public reports indicate that the White River NATC program was marketed through intermediaries rather than sold directly by White River. Nepsis reportedly served as a primary distribution partner, and Nepsis in turn worked with financial advisers, investment adviser representatives, and other intermediaries to sell the credits to individual and business purchasers. These sellers — many of them FINRA-registered brokers and SEC- or state-registered investment advisers — may have received fees or other compensation in connection with these transactions.
Financial advisers generally have regulatory obligations to conduct reasonable due diligence before recommending any product or strategy to a client. Under Regulation Best Interest, FINRA-registered brokers must exercise reasonable diligence, care, and skill and have a reasonable basis to believe that a recommendation is in the client’s best interest. Investment adviser representatives operate under a fiduciary duty — the highest standard of care recognized by law — requiring them to act in the client’s best interests and to disclose all material risks. Federal officials stated that these purported credits do not exist. Financial advisers who recommended the NATC program without identifying the risks associated with the credits may have failed to conduct adequate due diligence their clients were entitled to receive.
Investors who purchased these credits may have claims against the advisers involved, the supervising broker-dealer or advisory firm, and any firm that earned revenue from facilitating the transactions. Certain purchase agreements reportedly contain language preserving buyers’ fraud claims against all sellers and distributors. Consistent therewith, lawsuits and arbitrations have been filed involving the sale of these so-called “tax credits.”
If you purchased White River Energy Native American Tax Credits and later received IRS rejection notices, were assessed penalties, or experienced financial losses, contact Peiffer Wolf at 585-310-5140 or by filling out an online contact form for a FREE Consultation. Because legal deadlines may apply, it is important to seek legal advice promptly.
According to court filings, Justin and Robin Daniels of Jupiter, Florida paid approximately $1.62 million for White River NATCs. Court filings state that the IRS rejected their 2023 return and assessed a penalty of approximately $149,009. White River reportedly defaulted in a Palm Beach County circuit court case involving the Daniels’ claims. A Texas purchaser allegedly wired approximately $750,000 for credits (signed on December 18, 2024) — one day before the Bloomberg exposé — and subsequently filed a federal lawsuit alleging White River and Nepsis refused to issue a refund. A Florida physician reportedly wired funds in January 2025; according to filings, Nepsis kept the money and in April 2025 told him they could no longer file the credits on his return. A Louisiana business owner recently filed suit after allegedly paying $1.2 million for approximately $2 million in “credits,” only to have them disallowed by the IRS.
Senator Ron Wyden has stated that sales of the purported tribal tax credits may exceed $100 million.
In August 2025, the IRS updated its Internal Revenue Manual with guidance instructing agents to disallow claimed sovereign tribal tax credits as a scheme and directing agents that such credits are not allowed “regardless of the amount claimed or the type of documentation provided.” The IRS references several terms used by promoters, including “Sovereign Tribal Federal Tax Credit” and “Native American Tribal Credit.” If you claimed any of these credits on a federal tax return — or were advised to do so — you should consider seeking legal advice promptly. Contact Peiffer Wolf at 585-310-5140 or by filling out an online contact form for a FREE Consultation.
Peiffer Wolf is currently investigating claims on behalf of purchasers of White River Energy Native American Tax Credits, regardless of which adviser or tax professional recommended or facilitated the purchase. If any of the following describe your situation, contact us immediately:
Contact Peiffer Wolf at 585-310-5140 or by filling out an online contact form for a FREE Consultation. Any claim is subject to statutes of limitation and other filing deadlines, so it is important to seek legal advice promptly.
Peiffer Wolf Carr Kane Conway & Wise has represented thousands of victims of investment fraud and broker misconduct, and we remain committed to fighting on behalf of investors. Our firm has recovered hundreds of millions of dollars for harmed investors across the country. If you or someone you know purchased White River Energy tribal tax credits, contact us today.
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Beginning in late 2023, White River Energy Corp., through distributor Nepsis Tax Advisors LLP and a network of financial advisers and other intermediaries, marketed “Native American Tax Credits” (also called “Sovereign Tribal Federal Tax Credits”). Promotional materials suggested buyers were told they could pay roughly 60 cents per $1 of federal income tax credits and claim them on their returns, implying a potential 67% return. Purchasers typically wired at least $100,000 to a Nepsis Tax Advisors bank account at U.S. Bank in Minneapolis. Purchasers then received a “Tax Credit Certificate” to attach to their IRS filings. The credits were represented as issued by a Native American tribe and registered with the U.S. Treasury; White River publicly claimed to have registered $64 billion by March 2024.
No. Bloomberg reported on December 19, 2024 that U.S. Treasury officials said no such credits exist, and the IRS formally confirmed in writing to the Senate Finance Committee on March 21, 2025 that the credits “do not exist.” In August 2025, the IRS updated its Internal Revenue Manual, referencing “sovereign tribal tax credits” as a scheme and directed agents to disallow all such credits “regardless of the amount claimed or the type of documentation provided.” As a result, Purchasers who claimed these credits on a tax return have had — or will have — that claim rejected by the IRS. Bloomberg also reported that the Cherokee Nation issued a cease-and-desist to White River.
Taxpayers who claimed these credits have reported that they have had their returns rejected and face civil penalties—often 20% or more of the disallowed amount—plus potential interest. The IRS also warned that taxpayers could face civil penalties in its March 2025 letter to Congress. Real-world examples include a Florida couple who reportedly paid approximately $1.62 million for credits, had their 2023 return rejected, and were assessed a $149,009.86 penalty. Others purchasers who wired funds close to or after the Bloomberg report have reported refusals to refund purchase prices and are now in litigation. The IRS has instructed agents to disallow these credits promoted under various names, including “Sovereign Tribal Federal Tax Credit” and “Native American Tribal Credit.”
Public reports indicate that the White River NATC program was marketed through intermediaries rather than sold directly by White River. Nepsis reportedly served as a primary distribution partner, and Nepsis in turn worked with financial advisers, investment adviser representatives, and other intermediaries to sell the credits to individual and business purchasers. These sellers — many of them FINRA-registered brokers and SEC- or state-registered investment advisers — may have received fees or other compensation in connection with these transactions.Under Regulation Best Interest, FINRA-registered brokers must exercise reasonable diligence, care, and skill and have a reasonable basis to believe that a recommendation is in the client’s best interest. Investment adviser representatives operate under a fiduciary duty — the highest standard of care recognized by law — requiring them to act in the client’s best interests and to disclose all material risks. Federal officials stated that these purported credits do not exist. Financial advisers who recommended the NATC program without identifying the risks associated with the credits may have failed to conduct adequate due diligence their clients were entitled to receive.Investors who purchased these credits may have claims against the advisers involved, the supervising broker-dealer or advisory firm, and any firm that earned revenue from facilitating the transactions. Certain purchase agreements reportedly contain language preserving buyers’ fraud claims against sellers and distributors, and multiple lawsuits and arbitrations have already been filed.
Because legal deadlines may apply, you should consider seeking legal advice promptly. If the IRS has rejected your claim, assessed penalties or interest, sent a notice of examination, or if you wired money to Nepsis and have not received a refund, contact counsel promptly because claims are subject to statutes of limitation. Peiffer Wolf is investigating these matters and offers a Free Case Evaluation. You can Contact us at 585-310-5140 or by filling out an online contact form. We represent investors nationwide in fraud and broker-misconduct cases and have recovered hundreds of millions of dollars for harmed investors.