Our Practices
Tax Controversies
Tax Investigations and Defense
No one looks forward to being audited, but we can make the process less stressful by helping our clients produce only the necessary documentation and forcefully advocating on their behalf with federal and state tax authorities.
While under audit, issues may arise that while not necessarily illegal, may give the appearance of improper conduct.
Criminal Tax Investigations and Audit Defense
A civil tax audit at times may lead to a referral to Criminal Investigations (CI) if the civil agent believes that the taxpayer willfully committed tax fraud.
It is critical for anyone with a tax return or books and records that may be perceived by a revenue agent or revenue officer to contain ‘badges of fraud’ to immediately pause the audit and invoke his or her rights to engage an experienced taxpayer representative. Commonly referred to as ‘egg shell’ audits, we can navigate these fact sensitive issues and have a track record of successfully steering these matters clear of a criminal referral, or if already referred to CI, persuaded CI to have the exam returned to a civil track.
- Estate and Income Tax Planning
- Wealth Preservation (NINGs, DINGs, SLATs, GRATs)
- Special Needs Planning
- Special Purpose Trusts
- International Estate & Tax Planning for Non-Citizen U.S. Residents
- 1031 Exchange
- Qualified Opportunity Zone Program
- QSBS Planning
- Tax Residency: Snowbird Counsel
- Estate and Trust Administration
- Business Succession Planning
- Corporate Tax & Reorganization
- Tax Controversies
- IRS & State Tax Collection Defense
- Sales & Use Tax
- Tax Investigations and Defense
- IRS & State Voluntary Disclosures & Compliance
- International Tax
- Trusts & Estates Litigation, Guardianships and Fiduciary Counseling