Tax Controversy and Compliance
We advise, represent and guide clients through all stages of tax controversy matters at the U.S. federal, state and local levels. We advise individuals and companies in connection with audits and other tax examinations by the IRS and the New York State and City taxing authorities and provide representation at conciliation conferences and other administrative appeal procedures. In the instances when matters cannot be satisfactorily resolved at the audit or administrative appeals level, we represent clients in administrative hearings, judicial trials and at administrative and judicial court appeals.In addition to federal tax examinations dealing with a variety of issues, we frequently represent individuals in New York State and/or New York City residency related and other income tax examinations. We advise and advocate regarding issues of domicile (permanent home), statutory residency (based on time spent in New York) and characterization and allocation of nonresidents' income. We represent corporations, partnerships and other entities before the New York State and New York City taxing authorities in examinations relating to franchise taxes, unincorporated business taxes and other business related taxes. We advise and represent clients in sales and use tax audits and examinations relating to excise taxes or other activity-targeted taxes.
We advise in connection with and prepare, file and prosecute claims for refund of taxes at the federal, state and local levels. We provide counsel on penalty abatement and the satisfaction of assessed tax liabilities, prepare penalty abatement requests and negotiate closing agreements. We assist clients in securing and negotiating offers in compromise or payment plans for the satisfaction of outstanding tax liabilities. We advise individuals regarding innocent spouse relief and other claims eliminating or limiting their liability for taxes.
We advise on matters relating to past noncompliance with tax reporting or payment obligations. We advise and assist clients in filing amended tax returns, making voluntary disclosures and with other compliance measures. We advise clients with undisclosed offshore financial accounts and other financial assets regarding income tax and "FBAR" penalty issues and compliance alternatives. We represent clients entering the IRS's offshore voluntary disclosure program including clients utilizing the "streamlined" procedures.
We advise on the tax issues which may be releveant in non-tax litigation, including corporate and other commercial litigation, as well as marital or other family disputes. We consult with non-U.S. counsel regarding the fiscal issues relating to non-U.S. tax controversies.