CLIENTS AND REPRESENTATIVE MATTERS

• We represent a vast array of businesses across the United States in matters before the IRS, in the United States Tax Court, and in Federal District Court involving Federal income tax issues arising from welfare benefit funding.  
   
• We represent Virgin Island Economic Development Companies and their principals in matters – both civil and criminal -- before the IRS and in the United States District Court.  
   
• We represent companies on a variety of international tax issues involving United States/Canada cross border transactions.   

• We assist clients holding off-shore bank accounts with Foreign Bank Account Reporting (FBAR) compliance.
   
• We achieved favorable results for an international magazine publisher on federal income and withholding tax matters with the IRS.  
   
• We achieved favorable results on complex capitalization issues before the IRS for a Canadian technology corporation that relocated to the United States.  
   
• We achieved favorable resolutions for corporations on extraterritorial income exclusion issues in fast-track mediation proceedings with the IRS.  
   
• We represent individuals in District Court and before the IRS regarding theft losses perpetrated by securities dealers and companies.  
   
• We achieved an innovative and favorable resolution with IRS on behalf of individuals who participated in a "Son of Boss" transaction.
   
• We represent a medium-sized corporation in a complex employment tax IRS examination.   
   
• We represent high income, high net worth individuals in a multi-million dollar malpractice action against a national promoter of abusive tax shelters relating to a customized tax shelter that IRS has identified as a "listed transaction."  
   
• We represent a large retailer in defense of an indictment charging it with structuring, money laundering, mail fraud, tax fraud, forfeiture and other white collar offenses.    
   
• We represent an individual in a joint IRS, New York State, New York City examination involving scrutiny of taxpayers who at some time owned an offshore bank account or repatriated monies utilizing such an account.  
   
• We represent corporate and individual taxpayers in District Court and before the IRS against the new Section 6707A “jumbo penalties” asserted by the Internal Revenue Service for failure to report so-called Reportable Transactions.   
   
• We represent a New York business seeking to increase its sales volumes through an additional joint venture involving a foreign partner, new capital formation sources, and expansion of markets to include other states and Canada.     
   
• We represent a New York business in its owners’ desires to gradually phase out of active operations, sell the customer list and good will, and plan for life's retirement phase.

• We represent a large corporate taxpayer in Federal District Court on employment tax and penalty litigation.