Effective and timely advice, provided by experienced counsel, is crucial when the IRS, state or local government comes to audit your tax return, collect a delinquent tax liability or request the disclosure of a foreign bank account. Unforgiving procedural deadlines and admissions made by the taxpayer without guidance can close off opportunities to defend your position; the importance of skilled advocacy, combined with experience, cannot be understated. We represent clients on all types of tax deficiencies, collection matters, refund claims, and compliance matters involving income taxes, payroll taxes, trust fund recovery penalties, foreign bank account reporting (FBAR), excise taxes, estate and gift taxes, sales and use taxes, and related penalties and interest. Our objective is to resolve each client’s unique tax dispute as quickly and efficiently as possible.
Audit Examination & Defense
An IRS, state or local government audit can disrupt your personal affairs and business operations. If not handled properly and left uncontrolled, tax audits can adversely affect relationships with your spouse, business partners and shareholders, and could substantially reduce company profits. Our federal, state and local government tax audit and examination defense practice covers the entire process, from the initial Information Document Request through audit, administrative hearings, appeals, and litigation, if necessary. Our attorneys have successfully resolved numerous federal and state audit and collection cases, including, personal income; corporate income; sales and use tax; employment tax; trust fund recovery penalty; and business and professional occupancy tax throughout Virginia and the surrounding Mid-Atlantic region.
Being subject to the IRS or state tax collection process is traumatic. Taxpayers face possible wage and income garnishments, bank account levies, the shuttering of a business, and asset seizures. Our tax collection practice will help you end the collection process by removing levies, garnishments and liens, amending and correcting previous tax returns, filing delinquent tax returns, and negotiating with the IRS and state governments to reduce your liability and/or establish a reasonable payment plan. Whether you need advice regarding your first proposed assessment notice, representation at a Collection Due Process (CDP) hearing, submitting an Offer in Compromise (OIC), or are facing an immediate bank account levy, we can assist you during any phase of the collection process.
Foreign Bank Account (FBAR) Compliance
The IRS and Department of Justice are focusing their enforcement efforts on identifying and pursuing U.S. citizens (living in the U.S. and abroad) and businesses with unreported foreign accounts and foreign assets. Failure to disclose the existence of foreign accounts can lead to severe civil penalties and potential criminal prosecution. Whether a taxpayer is already under investigation or is considering his or her options in coming into compliance, we can assist with resolving past non-compliance with Foreign Bank Account Reporting (FBAR) and voluntary disclosure, including use of the IRS offshore Voluntary Disclosure Program (OVDP), Streamlined Filing Compliance, Delinquent Submission Procedures and Quiet Disclosures.
Tax Return Preparation
In addition to our audit resolution, tax collection and FBAR compliance practice, we also prepare individual, estate, gift and fiduciary income tax returns for our clients. Whether preparing multiple returns in the context of an audit, amending a previously incorrect return or simply preparing a current year return, our tax professionals provide insightful tax information and tax saving strategies for individuals, trusts and estates. Because our tax system is constantly changing and increasing in complexity, our goal is greater than simply preparing your return, it is to ensure the tax ramifications of your business and financial decisions are carefully considered to ensure you are paying the least amount of tax possible.