Tax Audits & Administrative Appeals
We represent individuals, corporations, partnerships, and estates before the Internal Revenue Service in tax audits. In some cases, audit issues are worked-out in the IRS Appeals unit; we have deep experience with IRS Appeals and we routinely prepare protests and negotiate with IRS Appeals to achieve favorable results. We also represent clients before state taxing authorities in tax disputes, including sales/use tax audits and personal income tax audits.
Tax Penalty Abatements
The firm is exceedingly effective in securing the abatement of domestic tax penalties (e.g., failure-to-file, failure-to-pay, failure-to-deposit, trust fund recovery penalty) and international tax penalties (e.g., late-filed international information returns (Form 5471, Form 5472, Form 3520), late-filed FinCen Form 114/FBAR). We have secured millions of dollars in penalty abatements for our clients.
International Tax Compliance Consulting/Undeclared Offshore Bank Accounts
We advise US taxpayers with worldwide income and assets – as well as foreign clients with US activities – on their US tax and reporting obligations. In addition, we counsel US taxpayers with undeclared foreign financial accounts and assets on their US reporting obligations – and assist them in coming into compliance. We have succeeded in taking scores of clients with undeclared foreign financial accounts into compliance.
Tax Controversy Consulting
Tax accounting firms and other specialty tax firms oftentimes require a tax controversy resource to handle routine (and sometimes no-so-routine) controversy and tax practice/procedure issues – from resolving a tax penalty issue to ensuring that a tax position reported on a return meets the required level of confidence. We provide on-demand tax controversy consulting services to tax accounting firms and specialty tax firms throughout the United States.
Tax Research/Tax Opinions
The firm has extensive tax research resources, and individuals, businesses, and tax accounting firms rely on us to research and explore thorny tax issues. In many instances, once we’ve resolved an issue, we memorialize our findings in a tax opinion letter or a tax memorandum. Our tax research projects have covered a large swath of tax areas – e.g., international tax, corporate tax, partnership tax. We also routinely provide tax research to clients on state tax issues (e.g., sales tax, use tax, personal income tax).
IRS collection enforcement actions strike fear into individuals and businesses alike. The firm’s collection practice has decades of experience in dealing with the IRS collection unit and related IRS units (e.g., the IRS lien unit, the IRS offer-in-compromise unit). We routinely handle lien issues, levy issues, and represent clients in collection due process hearings and in collection appeals program hearings. We have successfully negotiated scores of installment agreements and offers-in-compromise with the IRS.
Worker Classification Consulting/Audits
Is your worker an employee or an independent contractor? A worker’s mischaracterization can have significant tax – and penalty – consequences. We routinely counsel businesses on worker characterization issues (e.g., responding to a Form SS-8 filed by a former, disgruntled “employee”) and represent clients in worker classification audits.
Private Letter Rulings/9100 Requests
The firm has deep experience in securing favorable private letter rulings and 9100 relief rulings from the IRS National Office. The private letter ruling process is complex. We have handled scores of ruling requests and are skilled at not only preparing the requests but successfully shepherding the requests through the administrative process.
Closing Agreements & Pre-Filing Agreements
The firm is well-versed in IRS practice and procedure and has decades of experience in negotiating and securing favorable IRS closing agreements and pre-filing agreements for business and individual clients alike. Resolving a tax problem not only requires a deep understanding of the relevant tax law it requires a deep knowledge of the numerous administrative remedies available to a taxpayer to fix the problem. The closing agreement process enables a client to clean-up a newly-discovered - but pre-existing - tax problem. The pre-filing agreement process provides a client with the ability to address a potential tax problem before it reduced to a tax position on a future tax return.
Federal Reportable Transaction Counseling
The reportable transaction rules and material advisor rules are complex, and a miscalculation in navigating the rules can expose you or your company to staggering penalties. We have deep experience in the reportable transactions/material advisor rules – including developing reportable transaction compliance programs for multinational businesses. If you have a reportable transaction issue or a material advisor issue, we can help.
Tax Risk Management/Circular 230 Consulting
From Circular 230 to the AICPA Code of Professional Conduct, there are a host of ethical standards governing tax accounting firms and CPAs. The firm has deep experience in counseling accounting firms and tax professionals on tax ethics and related tax risk management issues. We also provide one-hour or two-hour seminars on tax ethics issues for clients and tax-related organizations alike.
Tax Treatment of Legal Settlements & Judgements
State Tax Controversies
The firm has been involved in state tax controversies and state tax controversy issues throughout the United States. From California estate tax issues to Pennsylvania sales/use tax audits, we can assist you with your state tax issue.