We are an experienced tax law firm serving clients nationwide.
We assist clients in all types of tax matters including:
- IRS Tax Audi
t Representation and Defense - IRS Audit Reconsideration and Reopening of Closed Tax Audi
t s - IRS Tax Appeals and Administrative Appeal Representation
- IRS Tax Collection Defense, Levies, Liens, and Wage Garnishment Cases
- Federal Tax Litigation in U.S. Tax Court, District Court, and Court of Federal Claims
- Foreign Asse
t Tax Planning and International Tax Compliance - Offshore Tax Planning and Foreign Bank Account Reporting Compliance
- IRS Voluntary Disclosure Planning for Unreported Income and Offshore Accounts
- Offshore Voluntary Disclosure Program (OVDP) Representation
- Streamlined Domestic Offshore Procedures (SDOP) for U.S. Taxpayers
- Streamlined Foreign Offshore Procedures (SFOP) for Expats and Foreign Residents
- Delinquent FBAR
t Compliance - Criminal Tax Defense, Tax Fraud Investigations, and IRS Criminal Investigations
- IRS Offers in Compromise and Tax Debt Settlement Representation
- IRS Tax Settlements for Back Taxes, Penalties, and Interest
- Individual and Business Income Tax Audi
t Defense - Payroll Tax Audi
t Representation and Employment Tax Disputes - Sales Tax Audi
t Defense and State Tax Controversy Representation - Trust Fund Recovery Penalty Defense for Business Owners and Responsible Persons
- Estate Tax Return Preparation and Gift Tax Return Preparation
- IRS Penalty Abatement for Failure to File, Failure to Pay, and Accuracy Penalties
- IRS Notice Response and Tax Notice Representation
- IRS Appeals Representation for Audits, Collections, and Penalties
- IRS Installment Agreement Representation for Tax Debt Payment Plans
- Non-Filer Tax Return Preparation and IRS Non-Filer Representation
- Private Letter Ruling Requests from the Internal Revenue Service
- Estate and Gift Tax Planning for High Net Worth Individuals and Families
- Individual Tax Planning to Reduce Income Taxes and Capital Gains Taxes
- Business Tax Planning for Corporations, Partnerships, LLCs, and Small Businesses
- IRS Levy Release, Bank Levy Defense, and Wage Garnishment Relief
- IRS Tax Lie
n Withdrawal, Subordination, and Release Services - Innocent Spous
e Relief and Injured Spouse Tax Relief Claims - Payroll Tax Debt Resolution and Employment Tax Collection Defense
- Back Tax Resolution and Unpaid Tax Debt Negotiation
- Tax Court Petitions and IRS Litigation Defense
- Foreign Bank Account Reporting (FBAR) Compliance and Penalty Defense
- FATCA Compliance and Foreign Financial Asset Reporting
- Unreported Offshore Account Disclosure and Offshore Penalty Defense
- Cryptocurrency Tax Compliance, Digital Asset Reporting, and IRS Audit Defens
e - Business Tax Controversy, Partnership Tax Disputes, and Corporate Tax Defense
- IRS Seizure Defense and Asset Protection in Tax Collection Cases
- Tax Fraud Defense and Civil Fraud Penalty Representation
- State Tax Audi
t Defense and Multi-State Tax Controversy Services - IRS Collection Due Process Hearings and Appeals
- Wage Levy, Bank Levy, and Property Seizure Defense
- Tax Debt Relief Services for Individuals, Businesses, and Self-Employed Taxpayers
Representative Tax Matters
Past results do not guarantee future results.
Voluntary Disclosure & Offshore Compliance
- Counseled over 1,000 clients in various 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 clients in Voluntary Disclosure Practice (VDP) submissions to the IRS involving previously undisclosed offshore assets, successfully avoiding criminal prosecution and minimizing penalties.
- Advised and prepared hundreds of Delinquent International Information Return Submission Procedure (DIIRSP) cases with the IRS on behalf of U.S. taxpayers who failed to file international information returns Forms 8938, 5471, 3520, and/or 3520-A, persuading the IRS that reasonable cause existed and resulting in no penalties.
- Advised and prepared hundreds of Delinquent FBAR
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
0
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.
- Represented a client in an IRS Collection Due Process (CDP) Hearing Office of Appeals, stopping collections and challenging proposed tax deficiencies. Negotiated a resolution significantly reducing the tax liability.
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 for unreported income, successfully resolving the matter without criminal prosecution.
- Represented a construction business owner under IRS criminal investigation for unreported check-cashing income, successfully resolving the matter without criminal prosecution.