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Taxation and Tax Controversy

We concentrate on the full spectrum of international, federal, state, and local tax issues, including tax planning and tax controversies.

We strive to provide cost-effective planning with the goal of creative and value-added tax solutions. The firm’s tax lawyers regularly undertake tax planning for C corporations, S corporations, partnerships, business trusts, limited liability companies, individuals, estates and trusts, and tax-exempt organizations.

We assist taxpayers with numerous IRS and New York State tax issues including non-filing of tax returns, audits, appeals, collection matters and voluntary disclosure. The firm’s tax lawyers have extensive experience dealing with the New York State Department of Taxation and Finance, and with all levels of the Internal Revenue Service, from the private letter ruling procedures, through the audit and Appeals Office at the local and regional levels. We represent our clients from the initial contact with the taxing authorities through the judicial process.

Our practice includes:

Taxation

  • Corporate, partnership, and joint venture planning, including choice of entity and check-the-box issues
  • Tax-free reorganization of business entities
  • Mergers, acquisitions, and dispositions of businesses and assets
  • Recapitalizations and debt restructurings
  • Utilization of net operating losses and other tax carryovers
  • Section 1031 like-kind exchanges
  • Capital gains and loss planning
  • Tax accounting issues

Tax Controversy

  • Offshore Voluntary Disclosure Program for individuals and entities
  • NYS residency audits and sales tax audits
  • Income tax audits
  • Non-filers of NYS and IRS tax returns
  • NYS and IRS Offers in Compromise and Installment Agreements
  • IRS liens and levies
  • IRS appeals and NYS conciliation conferences
  • NYS tax warrants, income execution and suspension of driver’s license
  • Subordination and discharge of liens for sale or refinancing of real estate
  • Responsible person assessments
  • NYS voluntary disclosure
  • Innocent Spouse relief

Voluntary Disclosure

  • Offshore Voluntary Disclosure Program for individuals and entities
  • Foreign Bank Account Reporting (FBAR) compliance
  • Penalty minimization strategies
  • Non-willful analysis
  • Evaluation and analysis with respect to Form 8938, Form 5471, Form 8865 and Form 8621
  • NYS voluntary disclosure for all tax types, for individuals, companies and estates