The complexity of international tax law necessitates a highly specialized skillset to successfully defend taxpayers’ positions on cross-border income matters before the IRS. Moreover, the audit and enforcement procedures followed by the IRS’s Large Business and International Division (LB&I) are different and stricter from those of any other audit initiating division of the IRS. Many of the traditional tax lawyering strategies, while very effective in purely domestic IRS disputes, would trigger the notorious IRS mandatory enforcement procedures in offshore and cross-border disputes which could yield disastrous results to the taxpayer. As such, it is critically important for advisors that defend international case audits to have a complete understanding of the LB&I’s bylaws, organizational structure and audit procedures.

We are the representatives of choice for U.S. taxpayers with foreign income and foreign taxpayers with U.S. income facing IRS audits and other enforcement actions. We have both the technical expertise and the procedural knowledge to challenge the IRS. We are also highly experienced in representing taxpayers in various IRS international voluntary disclosure and compliance programs. The following is a listing of some of the areas where our firm diligently represents clients in their dealings with the IRS and state revenue agencies:

  • Audits concerning foreign income and transactional disputes
  • Offshore Voluntary Disclosure Program (OVDP)
  • Streamlined Domestic Offshore Procedures
  • Streamlined Foreign Offshore Procedures
  • Unfiled international informational IRS forms
  • Foreign bank account reporting omissions (FBAR)
  • Collection actions, offers in compromise and due process hearings

We are also routinely hired to initiate Tax Court petitions and to serve as technical advisors in both the pretrial and trial phases of cases. We team with our network international tax attorneys and trial lawyers to ensure the most favorable court is selected for any given case. Call our Atlanta office at (770) 845-9289 to discuss your specific controversy matter today.