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Representative Matters: Tax: Business

  • Assisted both individuals and entities with making domestic voluntary disclosures under both IRS and state programs/procedures.
  • Represented large area technology and consulting company with overseas operations in contentious audit with IRS LMSB (Large & Mid Size Business) Division where government had issued summons to client and asserted potential tax assessment exceeding $1 million; audit eventually settled for fraction of original proposed assessment.
  • Represented corporate taxpayer in successfully seeking abatement and refund of multiple $10,000 per year penalties for late filing of IRS information returns for foreign subsidiaries (Form 5471).
  • Advised and represented various European based companies in establishing US presence while minimizing extent of US/State/local taxes and transfer pricing issues.