Undergoing an IRS audit can be a very stressful time for the taxpayer. IRS tax audits can also place serious financial and emotional burdens on individuals and businesses. These investigations are often stressful, time-consuming and intrusive. When businesses and individuals learn they may be the subject of an IRS investigation, they need to have a dedicated tax lawyer on their side to fully represent and protect their interests.
Unfortunately not all tax issues can be resolved at the IRS audit level. In these circumstances, Marini & Associates, P.A.’s skilled tax lawyers will navigate the client through the process of making a successful appeal to the IRS Office of Appeals (“IRS Appeals”).
Although most tax disputes are resolved through the during IRS audits and appeals procedures, if a favorable outcome cannot be achieved administratively, taxpayers have the right to litigate their cases in the federal court system. The United States Tax Court is the most common forum in which these types of cases are litigated. Cases involving IRS disputes can also be brought before the United States District Court and the United States Court of Federal Claims. Litigating a case in any of these federal courts is a challenging process and a successful result often hinges upon the skills of an experienced federal tax litigator.
IRS TAX COLLECTION DEFENSE
If you have been contacted by the IRS or a State or Local Tax Agency regarding a Tax Collection, including Levies, Liens, Garnishments and other collection actions, contact Marini & Associates, PA today for assistance representing and defending you from further Governmental Action!
TAX LIENS & TAX LEVIES
Tax liens and levies is a collection action by the Internal Revenue Service that can affect your wages, bank accounts, accounts receivables( if you're a business), your ability to obtain a loan and more importantly, the IRS can go after your assets.
INTERNATIONAL TAX LITIGATION
The Internal Revenue Service has committed to renewed efforts to pursue international violations of the tax laws by individuals and businesses. In order to address what it considers to be an area rife with abusive tax avoidance behavior, the IRS is aggressively pursuing international tax violations through use of both Civil Audits and Criminal Investigations and Prosecutions.
Taxpayers are seeing many countries, especially the US with its Foreign Account Tax Compliance Act (FATCA) and the OECD Countries Common Reporting Standard (“CRS”), making greater use of tax treaties and tax information exchange agreements, and engaging in more spontaneous disclosures of data from one taxing authority to another. With the post 9/11 focus on terrorism and money laundering and the increasing consensus that tax and fiscal crimes are just as serious as other offences, countries are exchanging tax information more freely.
The Criminal Investigation Division (CID) of the IRS works with startling efficiency in investigating and pursuing taxpayers who commit federal tax crimes.
It's not hopeless, since of the CID investigations initiated in 2015; almost 25% did not get recommended for prosecution! This means that you must work quickly and precisely to keep criminal matters from turning the corner.
If you or your business owes back taxes, penalties and interest will accrue until the tax liability is resolved or paid in full. Don't let penalties and interest accrued turn your tax liability into an overwhelming debt. Our firm deals with the IRS to reduce your tax debt and,in certain circumstances, may successfully waive or abate the penalties assessed against you.
INTERNATIONAL TAX PLANNING
US tax law is notoriously complex and ever-changing. The firm’s attorneys have over 100 years of combined experience in advising on laws, regulations, practices and procedures that impact clients and their businesses.
OFFSHORE TRUSTS & ASSET PROTECTION
The use of foreign trusts as asset protection devices for the high net worth United States client has in recent years received growing attention from an increasing number of United States advisors.
There are basically two steps you must take in order to surrender your U.S. Citizenship or otherwise known as "Expatriation." The first part involves the legal and political aspects of surrendering your citizenship which is handled by the U.S. State Department. The second part involves filing the required forms with the Internal Revenue Service and meeting all the requirements. In order to successfully terminate your citizenship, these two steps must be completed.
STATE & LOCAL TAX LITIGATION
Marini & Associates PA’s tax controversy and tax litigation attorneys have represented businesses and individuals before state and local taxing authorities in jurisdictions across the country. Marini & Associates PA’s representation includes assisting clients with state and local tax audits, challenging assessments, litigating contested tax issues, seeking refund claims before administrative tribunals and state courts, and advocating our clients’ positions before state appellate courts.
ESTATE & GIFT TAX LITIGATION
Marini & Associates PA’s tax litigators have extensive experience litigating federal estate, gift and fiduciary income tax disputes in federal and state courts across the country. For example, Marini & Associates PA has represented many corporate and individual fiduciaries, as well as charitable and educational institutions, in negotiating and litigating tax issues against the IRS. Additionally, Marini & Associates PA's tax controversy and litigation attorneys regularly represent clients in audits by, and appeals against, the IRS on estate and gift tax returns, fiduciary income tax returns and other tax-related issues including domicile disputes.
INTERNATIONAL PROBATE & ESTATES
As our world evolves, the ability of an individual to live, work or invest abroad becomes easier. With families becoming more internationally diverse, the result is that an increasing amount of individuals own assets in more than one jurisdiction. Our firm is has international probate attorneys that with experience in international estate cases. If you are an executor, administrator or beneficiary responsible for dealing with foreign assets, our international estate lawyers are here to help you to navigate the foreign legal requirements.
FORM 706, 706NA & 706QDT FEDERAL ESTATE TAX RETURNS
The federal Estate Tax is a tax on your right to transfer property at your death. It consists of an accounting of everything you own or have certain interests in at the date of death. The IRS form used for reporting is called the Federal Estate Tax Return, form 706. The fair market value of these items is used, not necessarily what you paid for them or what their values were when you acquired them. The total of all of these items is your "gross estate." The includible property may consist of cash and securities, real estate, insurance, trusts, annuities, business interests and other assets.