With our support and representation early in the process of an IRS initiated audit, our clients can significantly increase the likelihood of a favorable outcome at the end of the examination. One of our goals in managing your audit is to eliminate much of the anxiety in dealing with IRS Examiners and Agents allowing you to concentrate on the more important aspects of your life and business.

We are routinely called upon to handle and manage IRS audits (as well as examinations by various state and local taxing authorities) because of our substantial experience, consummate knowledge of the tax law and procedures, pragmatic approach, professionalism and interpersonal skills. Whether the audit involves domestic tax issues, international tax matters or both, we will assist you in positioning your case in the strongest light possible and vigorously defend your rights.

We have substantial experience in dealing with IRS Examiners and Agents, in carefully responding to Information Documents Requests (IDRs), and in defending clients against administrative summonses. We regularly assist our clients in strategizing and evaluating legal positions, and in employing appropriate alternative dispute resolution (ADR) proceedings during the audit, including Appeals Mediation, requests for a technical advice memorandum (TAM) and representation before the IRS Alternative Dispute Resolution Program Management Office (ADR PMO).

Illustrative engagements include:

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• An IRS examination of a multinational manufacturing and distribution group of companies involving both domestic and international tax issues (including transfer pricing). We resolved this case at the examination level with no proposed adjustments to our client’s income as originally reported.
   

• An IRS audit of a  Subchapter S corporation engaged in e-commerce and involving payments of royalties to licensees worldwide. We resolved this case with no proposed adjustments to our client’s income as originally reported.
   

• An IRS examination of a high-net worth individual owning interests in an assortment of US and foreign investments and businesses. We ultimately obtained a tax refund for our client in this case, subsequent to appealing Exam’s proposed adjustments before the IRS Independent Office of Appeals and employing various offsets, foreign tax credit and other techniques.
   

• An audit by the IRS of a taxpayer who made a “quiet disclosure” of amended tax and international information returns (including FBARs and Forms 5471 and 8938). In this case, we persuaded the IRS examiner to close the audit with no adjustments or penalties.
   

• A New York State Department of Taxation and Finance (NYS-DTF) examination relating to whether certain personnel of a multinational financial institution were independent contractors versus employees. We resolved the examination favorably by swaying the NYS-DTF that the personnel were indeed independent contractors.
   

• A District of Columbia Office of Tax and Revenue (DC OTR) examination of a Deed Recordation and Transfer Tax Return with respect to a specified real property. We resolved this case by convincing the OTR that the specified real property is exempt from DC Real Property Tax and that the transaction is exempt from DC Deed Recordation Tax.

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