Resolving issues with the Internal Revenue Service is stressful even for U.S.-based taxpayers.  When living overseas, the hassle is multiplied and numerous challenges can arise when attempting to address the underlying problems.   Our tax attorneys are well-versed in all aspects of IRS representation and will work with you to develop a tailored defense that accounts for the nuances of your specific situation. We will analyze your case and help you determine the best path forward.

Audit Representation

IRS audits come both in the form of formal examinations as well as ‘soft audits’, which is often an automated notice indicating that errors have been made on your tax return and you owe additional amounts. If you have received a notice from the IRS or have been selected for an audit, our team will represent your interests ensure that you don’t pay unnecessary taxes and penalties.

IRS Appeals Representation

If you have been representing yourself or working with a tax or accountancy firm to handle an IRS audit and are unsatisfied with the outcome, you will generally have 30 days from the conclusion of the audit to request a conference with IRS Appeals. Time is of the essence and an IRS Appeals Protest must be filed to preserve ability to challenge the tax liability without having to go to court. Our team can help you determine if you have rights that merit appeal and represent you through the ensuing process. Often the complexity of international tax issues leads to confusion and incorrect results in an audit context and utilizing the Appeals process is needed to arrive at the proper conclusion.

U.S. Tax Court Representation

For clients who have been unable to resolve their tax issues through the audit or appeals process, we will file a Tax Court petition on your behalf and develop an effective litigation strategy to challenge the taxes and penalties assessed against you. Many cases can be settled in advance of litigation, but if a settlement cannot be reached, our attorneys will aggressively represent your interests until all options have been exhausted.

State Department of Revenue Assistance

All states have different rules with respect to continuing tax liability once a resident moves overseas. Analyzing residency status under the patchwork of state-level guidelines will typically be the first step. While several states maintain ‘safe harbor’ rules allowing individuals who maintain ties to the state to clearly establish nonresident status, the path is not so straightforward in other locations.

To complicate matters, many states do not allow for many of the same international tax breaks that are available at the federal level, meaning that those deemed resident could face potential state tax bills even if nothing is due at the federal level. Our team focuses on assisting foreign-based American taxpayers with state residency audits and other compliance challenges.

FBAR and Foreign Information Reporting Penalty Abatement

U.S. owners of foreign trusts, businesses, and other assets often encounter difficulty determining U.S tax and related reporting obligations. Penalties for incorrect reporting or failing to file can be overwhelming.

Ensuring that businesses or investments are structured with an eye towards U.S. tax and information reporting obligations is important.  We can work with you to analyze the requirements applicable for both new and existing businesses.  And if these issues have not been handled properly and you are facing penalties, we will help you fight the case.