Services
If you’re looking for a firm that will focus on your individual needs, and always treat you like a client who matters, look no further. I offer a full range of professional services to give you the individual attention that you deserve.
I will thoroughly and conscientiously study your personal situation, and tailor my advice to your specific needs.
Employee Retention Credit (ERC) Issues
Applying for the ERC and whether you should withdraw an existing ERC claim with the IRS.
Business Entity Selection
The business entity—LLP, LLC, sole proprietorship, partnership, corporation, etc.— that you select for your business has enormous financial and tax implications. It is important that you make the right decision. I can explain each choice and its implications. As your business grows and changes, the type of business entity you choose may need to change also.
IRS Representation
I am experienced in income tax issues such as unreported income, IRA distribution issues, passive activity issues, information returns (Form 1099 or W-2) issues, back-up withholding issues, entity flow through issues, disallowance / adjustments for claimed expenses, IRS denial of claims for refund or tax abatement and issues involving self-employment tax for self-employed.
Proposed penalty issues for failure to file and failure to pay due to reasonable cause. The criteria for establishing reasonable cause for a taxpayer is a major area of defense available for the taxpayer that is often not fully addressed during an examination.
In the international tax sector, delinquency penalties associated with information return filing requirements for foreign based corporations – Form 5471 and 5472.
Employment tax disputes involving IRS worker classification – employee v. independent contractor and whether certain compensation is subject to tax withholding. Employment tax returns (Form 940 and 941) involving late tax deposits, untimely tax deposits and other related penalties.
Exempt Organizations – TEGE Division
Tax exempt status issues (determination level) involving unfavorable determination (adverse determination) such as denial of tax exempt status, public charity or private foundation classification and private benefit v. public benefit issues.
Issues involving what federal income tax exemption status to apply for: charitable organization – 501(c)(3); civic organization / homeowners association – 501(c)(4); business league – 501(c)(6); and social clubs – 501(c)(7). There are other types of tax exempt organization categories that are available, but these are generally the most common types. Each Internal Revenue Code section has its own specific set of qualifying criteria.
Examination issues of tax exempt organizations include proposed revocation of tax exempt status, tax compliance issues, proposed unrelated business income tax (UBIT) and excise tax issues such as intermediate sanctions, excess benefits and self-dealing against the organization and disqualified persons.
Tax exempt status revocation issues include alleged failure to meet the operational test requirements, private benefit and inurement of assets to shareholders.
Sub-issues involving exemption from self-employment tax for ministers of a 501(c)(3) religious organization.
In addition, I am experienced in tax matters involving TEGE sub-divisions Federal, State and Local Governments (FSLG) and Indian Tribal Governments (ITG).