Tax Controversies and Litigation Practice
We represent clients in IRS audits and appeals involving employment, employee benefits and executive compensation tax issues, including worker reclassification, tax withholding and Internal Revenue Code Section 162 relating to deductibility of executive compensation as a reasonable and necessary expense. Whenever necessary we vigorously represent our clients in federal district and appellate courts, including the U.S. Tax Court.
We have considerable experience representing clients who have undisclosed and unreported offshore accounts in violation of the Foreign account Tax Compliance Act (FATCA) and the Internal Revenue Code. We advise these clients as to which path is most appropriate under their factual circumstances and we represent their interests in the Offshore Voluntary Disclosure (OVD) Program, the Streamlined Domestic Offshore Compliance Procedures, the Streamlined Foreign Compliance Procedures and Delinquent Filing Procedures.