{"id":5119,"date":"2022-07-01T17:54:23","date_gmt":"2022-07-01T21:54:23","guid":{"rendered":"https:\/\/gsmlawoffices.com\/?page_id=5119"},"modified":"2022-07-18T10:20:08","modified_gmt":"2022-07-18T14:20:08","slug":"representative-matters","status":"publish","type":"page","link":"https:\/\/gsmlawoffices.com\/representative-matters\/","title":{"rendered":"Representative Matters"},"content":{"rendered":"\n\n

\n\t\tRepresentative Matters\n\t<\/h2>\n\t\t\tClient Profile: Global Insurance Company<\/a>\n\t\tPROBLEM:
\n<\/strong>IRS required the company to implement a federal reportable transaction\/material advisor disclosure program for US operations\nRESOLUTION:
\n<\/strong>Designed\/developed a program and, working with company’s tax group and information technology group, was responsible for overseeing the program’s implementation\n\t\t\tClient Profile: Domestic Automotive Parts Manufacturer<\/a>\n\t\tPROBLEM:
\n<\/strong>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\nRESOLUTION:
\n<\/strong>Succeeded in abating the $400,000 penalty abated in its entirety\n\t\t\tClient Profile: Privately-Held Domestic Contract Staffing Services Company<\/a>\n\t\tPROBLEM:
\n<\/strong>Company’s former chief financial officer failed to make federal withholding tax payments resulting in an approximately $1 million tax liability\nRESOLUTION:
\n<\/strong>Negotiated offer-in-compromise settling company’s liability for approximately 20 percent of the total outstanding liability\n\t\t\tClient Profile: Publicly-Held Domestic Internet Telephony Services Provider<\/a>\n\t\tPROBLEM:
\n<\/strong>While engaged in a restricting 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\nRESOLUTION:
\n<\/strong>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\n\t\t\tClient Profile: UK-Based Consumer Products Company<\/a>\n\t\tPROBLEM:
\n<\/strong>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\nRESOLUTION:
\n<\/strong>Succeeded in having the $800,000 penalty abated in its entirety\n\t\t\tClient Profile: Publicly-Traded Foreign Bicycle Manufacturer<\/a>\n\t\tPROBLEM:
\n<\/strong>Company failed to file required international information returns and was assessed a $100,000 late-filing penalty\nRESOLUTION:
\n<\/strong>Succeeded in having the $100,000 penalty abated in its entirety\n\t\t\tClient Profile: Professional Employer Organization<\/a>\n\t\tPROBLEM:
\n<\/strong>Company’s former chief financial officer failed to pay federal withholding taxes for several years resulting in an approximately $2.7 million liability\nRESOLUTION:
\n<\/strong>Negotiated an offer-in-compromise with the IRS settling the matter for approximately 20 percent of the outstanding tax liability\n\t\t\tClient Profile: Rural Cooperative Telephone Companies<\/a>\n\t\tPROBLEM:
\n<\/strong>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\nRESOLUTION:
\n<\/strong>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\n\n","protected":false},"excerpt":{"rendered":"

Representative Matters Client Profile: Global Insurance Company PROBLEM: IRS required the company to implement a federal reportable transaction\/material advisor disclosure program for US operations RESOLUTION: Designed\/developed a program and, working with company’s tax group and information technology group, was responsible for overseeing the program’s implementation Client Profile: Domestic Automotive Parts Manufacturer PROBLEM: Multinational company acquired domestic company’s assets and hired all of domestic company’s employees; IRS subsequently assessed a $400,000 […]<\/p>\n","protected":false},"author":3,"featured_media":0,"parent":0,"menu_order":0,"comment_status":"closed","ping_status":"closed","template":"","meta":{"site-sidebar-layout":"no-sidebar","site-content-layout":"page-builder","ast-site-content-layout":"","site-content-style":"default","site-sidebar-style":"default","ast-global-header-display":"","ast-banner-title-visibility":"","ast-main-header-display":"","ast-hfb-above-header-display":"","ast-hfb-below-header-display":"","ast-hfb-mobile-header-display":"","site-post-title":"disabled","ast-breadcrumbs-content":"","ast-featured-img":"disabled","footer-sml-layout":"","theme-transparent-header-meta":"default","adv-header-id-meta":"","stick-header-meta":"default","header-above-stick-meta":"","header-main-stick-meta":"","header-below-stick-meta":"","astra-migrate-meta-layouts":"default","ast-page-background-enabled":"default","ast-page-background-meta":{"desktop":{"background-color":"","background-image":"","background-repeat":"repeat","background-position":"center center","background-size":"auto","background-attachment":"scroll","background-type":"","background-media":"","overlay-type":"","overlay-color":"","overlay-gradient":""},"tablet":{"background-color":"","background-image":"","background-repeat":"repeat","background-position":"center center","background-size":"auto","background-attachment":"scroll","background-type":"","background-media":"","overlay-type":"","overlay-color":"","overlay-gradient":""},"mobile":{"background-color":"","background-image":"","background-repeat":"repeat","background-position":"center center","background-size":"auto","background-attachment":"scroll","background-type":"","background-media":"","overlay-type":"","overlay-color":"","overlay-gradient":""}},"ast-content-background-meta":{"desktop":{"background-color":"var(--ast-global-color-5)","background-image":"","background-repeat":"repeat","background-position":"center center","background-size":"auto","background-attachment":"scroll","background-type":"","background-media":"","overlay-type":"","overlay-color":"","overlay-gradient":""},"tablet":{"background-color":"var(--ast-global-color-5)","background-image":"","background-repeat":"repeat","background-position":"center center","background-size":"auto","background-attachment":"scroll","background-type":"","background-media":"","overlay-type":"","overlay-color":"","overlay-gradient":""},"mobile":{"background-color":"var(--ast-global-color-5)","background-image":"","background-repeat":"repeat","background-position":"center center","background-size":"auto","background-attachment":"scroll","background-type":"","background-media":"","overlay-type":"","overlay-color":"","overlay-gradient":""}},"footnotes":""},"aioseo_notices":[],"_links":{"self":[{"href":"https:\/\/gsmlawoffices.com\/wp-json\/wp\/v2\/pages\/5119"}],"collection":[{"href":"https:\/\/gsmlawoffices.com\/wp-json\/wp\/v2\/pages"}],"about":[{"href":"https:\/\/gsmlawoffices.com\/wp-json\/wp\/v2\/types\/page"}],"author":[{"embeddable":true,"href":"https:\/\/gsmlawoffices.com\/wp-json\/wp\/v2\/users\/3"}],"replies":[{"embeddable":true,"href":"https:\/\/gsmlawoffices.com\/wp-json\/wp\/v2\/comments?post=5119"}],"version-history":[{"count":14,"href":"https:\/\/gsmlawoffices.com\/wp-json\/wp\/v2\/pages\/5119\/revisions"}],"predecessor-version":[{"id":5240,"href":"https:\/\/gsmlawoffices.com\/wp-json\/wp\/v2\/pages\/5119\/revisions\/5240"}],"wp:attachment":[{"href":"https:\/\/gsmlawoffices.com\/wp-json\/wp\/v2\/media?parent=5119"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}