PROBLEM:
Multinational company acquired domestic company’s assets and hired all of domestic company’s employees; IRS subsequently assessed a $400,000 penalty against the domestic company for the intentional failure to file Forms W-2 in the acquisition year

RESOLUTION:
Succeeded in abating the $400,000 penalty abated in its entirety

PROBLEM:
Company’s former chief financial officer failed to make federal withholding tax payments resulting in an approximately $1 million tax liability

RESOLUTION:
Negotiated offer-in-compromise settling company’s liability for approximately 20 percent of the total outstanding liability

PROBLEM:
While engaged in a restructuring of its international subsidiaries, company determined that a foreign subsidiary failed to make an election to be treated as a corporation for US tax purposes at the time the subsidiary was formed some 10 years earlier; the missed election, if not successfully corrected, would have triggered substantial US tax liability

RESOLUTION:
Demonstrating to the IRS that the foreign subsidiary was permitted to make a late election (effective at the time of its formation); the IRS issued the company a private letter ruling memorializing the finding

PROBLEM:
Company failed to file numerous international information returns for a particular tax year; the IRS assessed a late-filing penalty in excess of $800,000

RESOLUTION:
Succeeded in having the $800,000 penalty abated in its entirety

PROBLEM:
Company failed to file required international information returns and was assessed a $100,000 late-filing penalty

RESOLUTION:
Succeeded in having the $100,000 penalty abated in its entirety

PROBLEM:
Company’s former chief financial officer failed to pay federal withholding taxes for several years resulting in an approximately $2.7 million liability

RESOLUTION:
Negotiated an offer-in-compromise with the IRS settling the matter for approximately 20 percent of the outstanding tax liability

PROBLEM:
Three rural cooperative telephone companies purchased spectrum some 10 years earlier with the intention of enhancing telecommunications services to their respective customers, but the enhancements were cost-prohibitive so the spectrum was not used; in year 10, a global telecommunications company purchased the cooperatives’ unused spectrum; the cooperatives were concerned that the sale proceeds constituted taxable income, which would have resulted in a collective tax liability exceeding $1 million

RESOLUTION:
Succeeded in demonstrating to the IRS that the proceeds from the spectrum sale constituted patronage sourced income and, in that regard, was not taxable to the cooperatives; the IRS issued a private letter ruling to each cooperative confirming this finding