We understand that dealing with tax agencies distracts clients from their business and personal goals. Clients receive our candid evaluation of their tax issues, and we work with them to reach an effective resolution. With our knowledge and experience, we make full use of all available procedures and defenses to achieve the best possible results as efficiently as possible.
Our practice includes the following:
Tax Audits and Administrative Appeals
Often through early involvement, we can limit the issues under examination and close the audit as efficiently as possible. We are experienced in dealing with sensitive or “eggshell” audits with potential exposure for civil or criminal fraud charges. We also represent clients in administrative appeals to reach a favorable settlement without the need for litigation.
With our extensive trial experience, we effectively litigate tax matters when the issues cannot be resolved to the client’s satisfaction at the administrative level.
Criminal Tax Defense
We represent clients in criminal tax investigations and prosecutions, both as targets and as witnesses.
Foreign Bank Account Reporting
We have helped many clients resolve tax and reporting issues related to their offshore financial accounts and arrangements, including failure to file necessary information returns and associated penalties.
Innocent Spouse Relief
We have successfully obtained relief from “joint and several liability” for tax obligations for former spouses. We also work closely with family law attorneys to ensure that tax matters are appropriately addressed during the dissolution and property settlement process.
Employment Tax Matters
We are experienced in controversies regarding the proper classification of workers as independent contractors or employees, as well as liability for withholding taxes (“trust fund penalty”) by responsible persons.
California Income Taxation of Trusts
Non-resident trustees and professional advisors may not fully understand California’s rules for taxing trust income, resulting in non-compliance and exposure to penalties, on the one hand, or overpayment of tax on the other. We are very familiar with the rules and procedures available to correct past filing errors.
We assist clients in filing and negotiating Offers in Compromise and Installment Agreements and obtaining relief from tax liens and levies.