Past results do not guarantee future results.
Voluntary Disclosure & Offshore Compliance
- Counseled over 1,000 clients in voluntary disclosure matters before the IRS, making the firm one of the most experienced IRS offshore and voluntary disclosure law firms in the country.
- Advised and prepared hundreds of Streamlined Domestic Offshore Procedure (SDOP) cases with the IRS on behalf of U.S. resident taxpayers who non-willfully failed to report foreign accoun
t s, investments, or income, achieving reduced 5% offshore penalties. - Advised and prepared hundreds of Streamlined Foreign Offshore Procedure (SFOP) cases with the IRS on behalf of U.S. non-resident taxpayers, achieving 0% penalty outcomes.
- Represented a client in a Voluntary Disclosure Practice (VDP) submission to the IRS involving previously undisclosed offshore assets, avoiding criminal prosecution and minimizing civil penalties.
- Successfully guided a client through the Delinquent FBAR
t s with no penalties assessed. - Represented a client in a Delinquent International Information Return Submission Procedure (DIIRSP) involving unfiled international information returns, persuading the IRS that reasonable cause existed and resulting in no penalties.
FBAR
- Represented numerous clients globally in correcting common FBAR
- Persuaded the IRS to abate FBAR
s . - Represented a client facing substantial proposed FBAR
Form 893
- Represented a client facing penalties for failure to timely file Form 893
8 (Statement of Foreign Financial Assets) and persuaded the IRS to abate all penalties. - Represented a U.S. owner of a foreign corporation facing Form 547
1 - Represented a client who received CP 15/CP 215 notices assessing Form 352
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Malta Pension Plan Matters
- Assisted dozens of taxpayers with compliance and solutions related to Malta Pension Plan problems amid IRS criminal and civil investigations.
- Represented a client who received an IRS summons related to a Malta Pension Plan, successfully resolving the matter.
- Counseled clients on coming into compliance with Malta Pension Plan reporting obligations following the IRS’s designation of certain Malta pension schemes as listed transactions.
Tax Audi
- Represented a client in an IRS income tax examination involving significant proposed adjustments. Persuaded the IRS Examination Division to abandon the proposed adjustments, resulting in substantial tax savings.
- Represented a client before the IRS Office of Appeals challenging proposed tax deficiencies. Negotiated a resolution significantly reducing the tax liability.
- Successfully represented a client in an IRS payroll tax audi
t , resolving proposed Trust Fund Recovery Penalties.
Tax Penalty Abatement
- Persuaded the IRS to abate penalties assessed against a client for failure to file tax returns, establishing reasonable cause for the late filings.
- Represented a client in a penalty abatement matter involving civil penalties, resulting in full abatement.
Tax Collection & Settlement Matters
- Represented a client in negotiating an IRS Offer in Compromise, settling outstanding tax liabilities for a significantly reduced amount.
- Obtained release of IRS wage levies and bank levies on behalf of a client facing outstanding tax liabilities.
- Secured release of federal tax lie
n s for a client, enabling continued business operations.
FATCA & International Compliance
- Represented a client in a FATCA disclosure defense matter, resolving recalcitrant foreign accoun
t issues with the IRS. - Counseled clients on foreign estate and gift tax planning involving foreign asse
t s, ensuring full compliance with U.S. reporting obligations.
Criminal Tax Matters
- Represented a client under IRS criminal investigation, successfully resolving the matter.