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Dedicated exclusively to complex civil and criminal tax controversies, providing strategic foresight to protect your assets.
Receiving an audit notice from the IRS or a state taxing authority is daunting. An audit is an adversarial process where the examiner’s goal is to maximize your liability. We step in between you and the auditor, controlling the flow of information and fiercely defending your returns to mitigate potential assessments.
When administrative remedies are exhausted and the IRS refuses to concede, taking them to court is often the best strategy. As former IRS Trial Attorneys, we are highly experienced litigators in the U.S. Tax Court, Federal District Courts, and Courts of Appeal, ready to fight for a favorable ruling.
The best defense against a tax controversy is preventing one from starting. We offer sophisticated tax planning and transaction structuring for high-net-worth individuals, entrepreneurs, and corporations to legally minimize tax burdens while ensuring strict regulatory compliance.
Tax penalties can quickly compound, sometimes doubling the original tax owed. We rigorously analyze your case to establish "reasonable cause" and other statutory defenses to successfully petition the IRS to reduce or entirely eliminate harsh civil tax penalties.
Cross-border taxation is incredibly complex. We guide expatriates, foreign nationals, and multinational entities through the maze of FBAR, FATCA, offshore voluntary disclosures, and international tax treaties, protecting against devastating non-compliance penalties.
If you have an assessed tax debt, the IRS has vast power to levy bank accounts and seize property. We intervene immediately to halt collections. Our team negotiates favorable resolutions including Offers in Compromise (OIC), Installment Agreements, and Currently Not Collectible (CNC) status.
