When clients face an IRS audit, collection action, penalty assessment, offshore reporting issue, or potential tax investigation, they need practical judgment, clear strategy, and counsel who understand how tax authorities evaluate risk. Our Tax Group brings that perspective to sensitive federal, state, local, and international tax controversy matters. Several of our attorneys previously served with the IRS, the Department of Justice, or the U.S. Tax Court, and that experience informs how we assess risk, negotiate with government personnel, and litigate when necessary in the U.S. Tax Court, federal district courts, and appellate courts throughout the country.
Our clients count on us to be engaged, responsive, and accessible when tax issues arise. We understand that audits and tax controversies can be intimidating, particularly for taxpayers with cross-border activity or who live abroad. We move quickly to assess the facts, preserve options, protect privilege and privacy, and develop a pragmatic strategy designed to reduce business disruption and long-term financial risk.
We regularly handle IRS audit and collection matters for taxpayers in the United States and overseas. Depending on the client's needs, we communicate directly with revenue agents, revenue officers, Appeals officers, settlement officers, and IRS Counsel, or we work behind the scenes with the client's accountant, internal tax team, or other advisors.
Our Tax Department includes attorneys located throughout the Firm's offices in Alabama, Florida, Georgia, Louisiana, Maryland, Mississippi, New Jersey, North Carolina, Tennessee, and Washington, D.C. Several of our attorneys are also certified public accountants, hold an LL.M. in Taxation, or have held relevant positions in private industry. Our federal, state, and local tax controversy capabilities include:
- IRS examinations and Appeals matters for individuals, LLCs, partnerships, and corporations in a wide range of industries in the United States and abroad;
- IRS practice and procedure;
- U.S. Tax Court litigation and refund actions;
- IRS collection matters, including collection due process and CAP hearings;
- Federal excise tax audits and refund claims;
- Civil and criminal fraud matters;
- Penalty and interest abatement requests;
- Tax lien releases, withdrawals, and subordinations;
- Levy and wage garnishment releases and withdrawals;
- Installment agreements and offer-in-compromise negotiations;
- Trust Fund Recovery Penalty matters;
- Notices of proposed deficiency and other examination-related notices;
- Private letter ruling requests and IRS technical advice memoranda;
- Fast-track mediation; and
- Federal and state amnesty programs.
We also counsel clients, including dual citizens, lawful permanent residents, U.S. persons living abroad, and foreign taxpayers with U.S. filing obligations on complex domestic and international tax compliance and planning matters, including:
- Unreported foreign bank accounts, foreign assets, and foreign income;
- Offshore voluntary disclosures and transition relief, including matters involving FBAR penalties;
- Foreign and domestic streamlined filing compliance submissions;
- Foreign Bank and Financial Accounts Report (FBAR) compliance;
- Global wealth planning;
- Pre-immigration and expatriation analysis;
- Form 3520, Form 5471, Form 5472, Form 8621, and related international information return issues;
- IRS National Office ruling requests, including Section 9100 relief for late or retroactive elections;
- Passive foreign investment company (PFIC) matters;
- Treaty-related analysis; and
- Penalty abatement requests for late-filed returns and information returns.
Representative Tax Controversy Capabilities:
- Examinations, Appeals, and Litigation: audits, Appeals matters, U.S. Tax Court litigation, refund cases, notices of proposed deficiency, and related IRS practice and procedure matters.
- Collections and Enforcement Defense: collection due process hearings, CAP hearings, installment agreements, offer-in-compromise negotiations, lien releases and withdrawals, levy and wage garnishment releases, and Trust Fund Recovery Penalty matters.
- Penalties, Fraud, and Voluntary Disclosures: civil and criminal fraud investigations, penalty and interest abatements, domestic voluntary disclosures, offshore voluntary disclosures, streamlined submissions, and federal or state amnesty programs.
- International Reporting and Cross-Border Compliance: FBAR compliance, unreported foreign accounts and income, Forms 3520, 5471, 5472, 8621, PFIC matters, treaty-related analysis, pre-immigration planning, and expatriation analysis.
- Rulings, Elections, and Administrative Relief: private letter ruling requests, technical advice memoranda, Section 9100 relief, Form 8300 compliance, and other IRS administrative relief matters.
Across these matters, we focus on early risk assessment, clear communication, coordinated advocacy, and practical resolution strategies tailored to the client's facts, objectives, and tolerance for risk.