Gregory S. Martinelli
Greg counsels businesses and individuals worldwide on ways to resolve or mitigate their US tax problems and tax disputes. He routinely represents clients before the Internal Revenue Service in examinations, penalty disputes, collection matters, and administrative appeals as well as represents clients in state tax disputes, including personal income tax audits and sales/use tax audits. Working with the IRS National Office, Greg has secured favorable private letter rulings and 9100 rulings for his clients as well as negotiated favorable closing agreements and pre-filing agreements. Greg counsels clients with foreign assets/activities as well as foreign clients with US activities on US tax compliance and tax reporting requirements, including issues relating to undeclared offshore accounts. Greg serves as tax controversy counsel to accounting firms throughout the United State and advises the firms on a variety of international, federal, and state practice/procedure and substantive tax matters.
Prior to opening his eponymous law firm in 2015, Greg was a senior director with BDO USA, LLP’s national tax controversy practice. Before joining BDO, Greg was a senior manager with Ernst & Young, LLP’s national tax controversy group in Washington, D.C.