Taxation
We firmly believe that our clients should not have to face the IRS alone. Whether for individuals or their businesses, we have experience with dealing with the IRS and understand the strategy involved in doing so.
We have extensive experience in federal, state, and local tax matters. Tax considerations often determine the form, and occasionally the viability, of tax-related transactions. We assist clients in handling all aspects of tax planning. Our goal is to provide tax advice that fits the business objectives of our clients.
We provide advice on the tax aspects of corporate reorganizations, acquisitions, spin-offs and other dispositions, joint ventures, financings, and restructurings. We also represent our clients in tax-sensitive transactions, from the initial stages to resolution. We provide these services for clients in several business sectors.
We have experience in all facets of tax controversy resolution, from audit to appeals to competent tax authority relief. In cases where a client has been served a deficiency notice, we file tax petitions on the client’s behalf and work to negotiate a settlement that eliminates or reduces their tax debt. In cases of an audit, our attorneys correspond with the IRS so you don’t have to and have successfully negotiated ____ deals for our clients to help mitigate their tax obligations and penalties that otherwise
Our attorneys include practitioners from business law firms and law professors. In addition to Juris Doctor degrees, some attorneys have earned additional post-graduate legal and professional degrees, including advanced degrees in taxation (LLM certification). Our attorneys work together to ensure that our clients have access to the best advice on a given issue.
From tax planning to tax controversy resolution, we have the experience and depth of capabilities to meet your challenges. We are committed to supporting your goals and helping you to achieve success.
Tax Law & Foreign Asset Compliance
In recent years, there has been a major crackdown by the IRS on reported foreign income and assets, with severe civil and criminal penalties being assessed. Without action on the client’s behalf the penalties assessed can be as much as fifty percent of the account balance for each year the client had signatory authority over the account. This means that the penalties assessed when the client is caught are likely to greatly exceed the value of the account.
We help our clients bring these assets into compliance with United States tax laws by qualifying our clients for the Offshore Voluntary Disclosure Initiative (OVDI). In most cases, this program will eliminate the criminal penalties and significantly lessen the civil penalties which the client would otherwise face. The OVDI program has a number of complex rules and regulations, and attempting to enter this program without the assistance of an attorney could have serious pitfalls.
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