Process of Tax Controversy – we can help you through the entire lifecycle
Navigating the intricate landscape of tax disputes can be daunting, but Ziering & Esman is here to support you at every stage of the process. We are committed to guiding you through all of your complex tax situations by leveraging our experience on your behalf. From first IRS correspondence, through audits and examinations, to administrative appeals and litigation, we provide comprehensive representation tailored to your unique circumstances.
Our attorneys begin with a thorough assessment of your situation, identifying potential risks and opportunities for resolution. We work diligently to develop a strategic plan that aligns with your objectives, whether it involves negotiating with tax authorities, challenging assessments, or pursuing litigation. Throughout the entire lifecycle of your tax case, we prioritize clear communication and transparency, ensuring you are informed and empowered to make decisions. We understand the stakes are personal and we are committed to achieving the best possible outcomes for our clients.
Audits and Examinations
Receiving a notice from the IRS can be a source of stress and uncertainty. We strive to guide you through the process with efficiency and empathy. Our practice is built on a foundation of knowledge and experience in handling a wide range of audits from individual taxpayers to complex corporate entities. Our attorneys analyze your financial records and identify key areas of concern, proactively working to develop a strategy that will address your specific needs and objectives. Taxpayers have rights, even if they are unaware of them or feel like they do not. Our goal is to protect your rights, minimize potential liabilities, and achieve the best possible resolution.
IRS Independent Office of Appeals
The IRS Independent Office of Appeals serves as a vital opportunity for taxpayers seeking to resolve disputes without the need for litigation. Preserving your rights to seek appellate review is an important consideration during an examination. We are adept at navigating this critical stage, leveraging our in-depth understanding of tax law and procedural intricacies to advocate on your behalf. From drafting a protest requesting a review from the Office of Appeals, to representing clients at an Appeals conference, or negotiating a settlement, we are dedicated to achieving the best possible outcomes for our clients. We draw on decades of experience to effectively present your case before the Office of Appeals. We will provide an honest assessment of the best possible outcomes based on our expertise to support you throughout the process.
Tax Litigation
Ziering & Esman attorneys have handled federal and state tax matters on behalf of individual and entity clients for years. Our experience has brought about successful resolution of tax cases while working with different divisions and departments of federal, state and local governments. When disputes with the IRS cannot be resolved at the administrative level, clients engage us to represent them in formal legal proceedings. These cases often involve complex legal arguments, a comprehensive understanding of the facts, and detailed financial analysis. Our attorneys bring a wealth of experience to meticulously prepare each case. We are client-focused, ensuring you are informed and involved at every stage of the litigation process.
Specialized Tax Controversy Topics
Voluntary Disclosure
The IRS introduced the Voluntary Disclosure program with the intention of bringing taxpayers into compliance without the fear of criminal prosecution. But this process is anything but straightforward, requiring representation just to understand its steps, risks, and procedures. Ziering & Esman attorneys have represented clients and achieved successful resolutions in traditional and offshore voluntary disclosure programs. We have represented hundreds of taxpayers who require alternative paths for compliance to include FBARs and various other information returns. Even when our clients do not have a full grasp of their own tax liability or exposure, we work with professionals to conduct internal investigations, identifying further areas of noncompliance, allowing clients to resolve all of their issues in the most effective manner possible.
Sensitive and High-Risk Audits
Sensitive and high-risk audits, known by tax professionals as “eggshell audits,” are civil examinations that carry high risk of criminal exposure. In an eggshell audit, even the slightest misstep can lead to significant legal repercussions, including criminal investigation. Our seasoned tax attorneys are adept at navigating these high-stakes situations with necessary care and precision. We approach each civil examination by identifying potential hazards and analyzing exposure. Great care must be taken not to make any intentional misrepresentation or omission to the IRS. Depending on the client’s facts and circumstances, we carefully tailor a strategy to resolve outstanding issues and advise our clients on tax compliance. Our firm is committed to maintaining the highest level of discretion and professionalism, ensuring that your case is handled with the utmost sensitivity.
Potential for Fraud
Anyone can find themselves in the middle of a fraud investigation without having committed fraud. Ziering & Esman is skilled at addressing and mitigating potential fraud issues. We have a successful track record of defending clients against allegations of tax fraud, utilizing our deep knowledge of tax laws and investigative techniques to develop robust defenses. Trust us to handle the intricacies of tax fraud audits with prudence and commitment.
International Tax Reporting
The intricacies of international tax reporting come with challenges that require thoughtful guidance and strategic solutions. Our firm is well-versed in the ever-evolving landscape of international tax reporting requirements, including compliance with FATCA, FBAR and other critical reporting requirements. We understand the challenges faced by individuals and entities with global financial interests, and we are committed to ensuring compliance while protecting your tax position. With a proven track record of assisting clients in minimizing exposure to penalties, Ziering & Esman provides tailored strategies that align with your unique international footprint. Whether you’re an expatriate, a multinational corporation, or an investor with overseas assets, we deliver comprehensive solutions that safeguard your interests and simplify your international tax reporting obligations.
FBARs
Our team understands the nuances of the Foreign Bank Account Report (FBAR) regulations, which mandate U.S. persons with foreign financial accounts exceeding $10,000 to file an annual report with the Treasury Department. Whether you seek guidance on your filing obligations or want to rectify prior mistakes, we are committed to developing personalized strategies and guiding you through the complexities associated with the FBAR filing requirements. We bring a successful track record of assisting clients in navigating the stringent FBAR requirements, ensuring that every detail is meticulously handled to minimize your risks or resolving prior noncompliance in accordance with a strategy tailored to your needs..
Penalty Relief
Ziering & Esman has a deep understanding of the particulars involved in seeking penalty relief, offering clients assistance in abating and mitigating tax penalties. Our team is adept at managing the complex IRS procedures and criteria for penalty abatement, whether due to reasonable cause, statutory exceptions, or administrative waivers. We recognize the financial strain and stress that penalties can impose, and we are committed to crafting strategies designed to effectively address your unique situation.
Complex Tax Collection Matters
The challenging landscape of tax collection requires a firm with the experience to guide clients to strategic solutions to resolve their tax debts. Our team is well-versed in dealing with the IRS and state tax authorities while handling intricate collection issues such as liens, levies, offers in compromise, and installment agreements. Unresolved tax liabilities can impact every aspect of your life, making our ability to successfully negotiate a collection alternative with tax authorities and achieve favorable resolutions the most important asset you can have.