Collection Matters and Offers in Compromise
Burch & Cracchiolo attorneys regularly deal with Internal Revenue Service and Arizona Department of Revenue collection personnel, representing clients who have been found to have underpaid income and employment taxes to find acceptable payment terms and, when the circumstances justify, we will work to secure uncollectible status for our clients. We have a high rate of success in securing the abatement of penalties. We are accomplished in helping clients deal with liens, levies and seizures, successfully negotiating withdrawals and releases, installment agreements and offers in compromise. We have also assisted clients in obtaining innocent spouse determinations, eliminating the tax liability of the innocent spouse entirely. Where appropriate, we advise clients as to the discharge of taxes in bankruptcy.
Asset protection strategies are often used to minimize the impact of taxation on an individual's wealth. These strategies aim to safeguard the assets of an individual against taxation by utilizing various legal and financial techniques. By utilizing tax-efficient investment vehicles, trusts, and corporate structures, individuals can protect their assets from excessive tax liabilities. Asset protection planning can help reduce estate taxes, capital gains taxes, and other taxes on income, dividends, and interest. In this way, asset protection strategies can help preserve wealth for future generations and ensure that individuals can pass on their legacy to their loved ones without the burden of excessive taxation.
Business and Corporate Planning
Business and Corporate Planning involves creating strategies for the operation and management of a company, including tax planning. Effective tax planning is a crucial aspect of corporate planning that aims to minimize tax liability while ensuring compliance with applicable tax laws and regulations. By understanding the complex tax code and regulations, corporate planners can advise businesses on structuring their operations to take advantage of available tax benefits, such as deductions, credits, and exemptions. This can help reduce the overall tax burden of a company, allowing it to retain more earnings for reinvestment and growth. With the constantly changing tax laws and regulations, business and corporate planners need to stay up-to-date to ensure their clients' tax strategies are always relevant and effective.
We represent clients in actions brought by the government to forfeit funds based on allegations of structured currency transactions and have been successful in securing the return of a large percentage of the funds seized.
IRS and Department of Revenue Examinations
Clients who engage Burch & Cracchiolo tax controversy attorneys from the very first indication of any issue with a taxing authority can take advantage of our considerable experience in handling tax examinations and the consequences thereof. We assist our clients to identify significant issues, develop key audit strategies, provide advice in responding to information document requests and IRS summonses, establish procedures to identify and protect privileged documents and establish appropriate document retention procedures in order to preserve evidence. In many instances, we are asked by clients to interface with IRS examiners throughout the examination, whereas in others, strategic reasons dictate that we provide advice while remaining in the background. Our goal is to provide the level of service that is most advantageous for our clients, given their specific circumstances.
We thoroughly evaluate the merits of complex tax issues and develop creative arguments in defense of proposed adjustments. Our lawyers prepare detailed, persuasive responses to the IRS’ proposed adjustments and written protests for those examinations that proceed to IRS Appeals.
As of February 2011, the IRS updated the Offshore Voluntary Disclosure procedures. Burch & Cracchiolo lawyers advise clients on the impact of these changes and help clients determine if they qualify for such disclosure. We assist clients in making a proper Voluntary Disclosure in both offshore and domestic cases, with the goal of reducing or eliminating penalties and avoiding criminal prosecution. Such disclosures may be advisable in cases of underreported income, unfiled returns, unreported overseas accounts and investments and many more. In addition, we assist clients who wish to participate in amnesty programs to ensure proper compliance with the terms and conditions of these programs.
Tax Litigation and Controversy Work
The Tax Law practice at Burch & Cracchiolo extends to the specialized area of Tax Litigation and Controversy. Our seasoned attorneys have a strong track record in resolving complex tax disputes at all levels, from audits and administrative appeals to litigation in federal and state courts. We represent individuals, businesses, and organizations in various tax matters, including income, estate, and gift tax disputes, employment tax issues, and controversies involving non-profit organizations. Whether you're dealing with an audit, disputing a tax assessment, or facing potential litigation, our team is dedicated to providing strategic advice and robust representation, ensuring our clients' best interests are protected in any tax controversy scenario.