Protection of IRS Tax Attorneys

Tax liability in the USA is crucial for the stability and successful development of international business. Misunderstanding the complex tax law and IRS requirements can lead to significant fines, account freezes, and legal proceedings that hinder the company’s growth and undermine its reputation.

If your business is facing an audit, claims, or investigation from the IRS, contact our IRS tax attorneys. We will protect your company’s interests, eliminate the risk of significant penalties, and ensure full compliance with U.S. tax law.

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What is the IRS tax service?

Internal Revenue Service, IRS, is a federal agency that is part of the U.S. Department of the Treasury and is responsible for administering tax laws and collecting taxes within the United States. The organization monitors compliance with the Internal Revenue Code, oversees the accuracy of calculations and completeness of tax payments by both individuals and companies, and also investigates cases of tax evasion.

Let us consider the key functions and powers of the IRS:

  1. Acceptance and verification of income tax returns from individuals and companies;
  2. Selective IRS audits to verify the accuracy of reported income and paid taxes;
  3. Identification and investigation of cases of intentional fraud, tax evasion, and other violations of tax law;
  4. Work with judicial authorities for criminal prosecution in case of serious violations of IRS tax law;
  5. The release of official publications on filling out declarations, rules for expense accounting, and processing benefits.

The IRS accumulates tax revenues, which form a significant part of the income for the federal budget of the USA. The efficiency of the service’s work determines the funding of government programs (security, healthcare, social security, etc.). The service monitors the accuracy of income, expenses, and payroll deductions accounting.

IRS audits contribute to identifying fictitious expenses, underreporting of revenues, and other abuses, supporting fair competition in the market. The service administers programs that allow for reducing the tax burden (child tax credits, educational credits, investment deductions).

If a taxpayer does not pay taxes, the IRS has the right to impose a tax lien on property, garnish income, and take other measures to collect debts. That is why it is extremely important to consult with a tax law specialist and make timely adjustments to business processes.

When do you need a lawyer for IRS tax cases?

In an ideal situation, interaction with the IRS is limited to correctly completing and filing returns, timely payment of taxes, or receiving due refunds. However, in practice, situations arise when a taxpayer requires professional legal assistance from IRS tax attorneys to protect their rights and minimize risks.

1. Conducting IRS audits

The IRS may review your reporting and request additional documentation on income, expenses, tax credits, and deductions. An IRS lawyer will help correctly prepare the necessary documents, formulate responses to the inspector’s questions, and avoid careless statements that could result in accusations of income concealment.

If during an audit IRS employees identify discrepancies or suspect underreporting of income, they may assess additional taxes and penalties. An IRS lawyer will evaluate the validity of the claims, challenge the audit results if necessary, and make every effort to avoid additional sanctions.

2. The emergence of tax debt and collection

If the taxpayer has not settled the debt with the IRS, the service may place a lien on property or initiate enforcement procedures (account seizure, wage garnishment). IRS attorneys negotiate with the tax service on debt restructuring, entering into an installment agreement, or an offer in compromise.

3. Accusations of tax crimes

Tax evasion is a serious criminal offense, threatening not only large fines but also imprisonment. IRS attorneys will develop an effective defense strategy and make every effort to mitigate the sentence or prove innocence. An experienced specialist will conduct a full analysis of the evidence, search for contradictions in the prosecution’s arguments, and defend the client’s interests in court.

4. International Tax Issues

Citizens and residents of the USA are required to declare foreign accounts, comply with FATCA and FBAR requirements. Violating these rules can lead to significant fines and criminal cases. An IRS lawyer will provide consultation on declaration obligations and tax law, assist with voluntary disclosure procedures, and help reduce penalties. The specialist will ensure compliance with taxation requirements for income from various jurisdictions.

5. Litigation with the IRS

If pretrial negotiations with the IRS did not lead to a settlement, the case may go to court. The IRS lawyer will gather the necessary evidence, prepare procedural documents, and defend the clients’ interests during the hearings.

6. Pretrial Agreements and Negotiations

In some cases, the IRS is willing to consider partial payment of debts if the taxpayer is unable to pay the full amount. An IRS lawyer will assess the chances of a successful agreement, gather the necessary evidence of financial hardship, and prepare arguments to defend the client’s position. The specialist will negotiate with authorized representatives on reaching a settlement agreement and ensuring confidentiality.

Interacting with the Internal Revenue Service (IRS) is a highly complex and stressful process for companies and individuals. Errors in reporting, overdue payments, and inaccuracies in documentation often lead to IRS audits, penalties, and even criminal prosecution. If you are facing any of these situations, contact experienced IRS attorneys. Specialists in tax law will help develop a reliable defense strategy, negotiate with the IRS, and, if necessary, represent your interests in court.

Audits and investigations by the IRS

Selective checks can be initiated based on risk-oriented sampling when the IRS system “notices” potential discrepancies or suspicious indicators in a return. Additionally, the initiation of IRS audits can be triggered by dissatisfied clients, partners, or employees who have filed a complaint with the regulator. If companies or individuals repeatedly submit incomplete or incorrect returns, the risk of an in-depth audit increases.

In the case of detecting underpayment, an additional bill with penalties and fines may be issued. If auditors detect intent in concealing income or falsifying reports, the IRS initiates an investigation under criminal law.

A qualified lawyer will help collect and systematize financial reports, contracts, and bank statements. An IRS lawyer can provide convincing explanations and evidence, challenge unjustified additional charges or procedural violations by the inspector. In the case of serious disagreements with the audit results, a complaint can be filed with the IRS appeals division or taken to tax court.

Protection against tax debts and debt collection

Sometimes the amount specified in the notice may contain errors or not take into account tax benefits/deductions. Upon receiving a Notice of Deficiency or other documents from the IRS, it is important to respond in a timely manner; otherwise, the service may proceed to strict collection measures. In cases of severe financial hardship, it is possible to achieve a suspension of collection, but the debt remains.

A qualified attorney will assess the client’s actual ability to repay the debt and prepare evidence for the IRS. If the IRS claims or imposed penalties are based on incorrect information, the attorney will be able to challenge them. An experienced specialist will develop strategies to preserve assets and continue operations without the risk of account freezes.

Criminal tax charges

Tax fraud is the deliberate concealment of income, the use of shell companies, or illegal schemes to evade taxes. Tax evasion is the intentional failure to file tax returns, improper inflation of expenses and deductions. Falsification of financial statements includes underreporting revenue, fictitious transactions, and double bookkeeping.

Potential fines can reach hundreds of thousands of dollars depending on the scale of violations. Proven tax evasion carries a penalty of imprisonment for up to several years.

The attorney reviews all materials collected by the IRS and the prosecutor’s office, identifies violations in their acquisition or interpretation. If there are mitigating circumstances and a willingness to cooperate, the specialist will help achieve reduced penalties or reach a pretrial agreement.

Seizure of wages and bank fines

The IRS can collect funds in several ways. Garnishment (withholding from wages) – the employer receives an order to deduct from wages until the debt is paid off. Levy (seizure of bank accounts) – the bank is required to freeze or withdraw funds from the taxpayer’s account in favor of the IRS.

Withholding can reach a significant portion of income, up to the deprivation of means of subsistence. Account seizures make many of the company’s operational expenses impossible. If the IRS violated procedure or incorrectly calculated the debt amount, an attorney can petition for the removal or suspension of measures. Entering into an Installment Agreement or Offer in Compromise allows for the release of the seizure if the taxpayer demonstrates good faith intentions and the ability to pay.

Tax liabilities and seizures

Tax Lien is an official registration of tax claims, effectively securing the IRS’s priority to receive funds from the sale of the taxpayer’s property. Its presence significantly reduces the ability to obtain loans, conduct transactions, and develop a business.

The IRS has the right to seize movable and immovable property to cover debts if voluntary payment has not been made. The seizure may extend to bank accounts, brokerage assets, and other sources of income.

To dispute or prevent such a decision, it is necessary to check whether notifications were sent on time and whether the taxpayer’s response deadlines were met. The attorney will assess whether there are procedural and factual grounds for canceling or suspending the lien/arrest.

How can our IRS tax dispute attorney help you?

In matters of IRS tax law, any mistake can lead to significant financial losses and damage business reputation. Effective protection of interests requires a comprehensive approach and deep understanding of American tax law. Our law firm provides professional support at all stages of interaction with the IRS: from audits to litigation.

1. Defense in tax disputes and representation before the IRS

Our experienced specialists will conduct a full analysis of IRS notices and requirements, prepare all necessary documents and explanations, and protect clients’ interests in cases of misunderstandings or errors by tax authorities. We handle the preparation of objections and appeals in case of disagreement with additional charges, negotiate the reduction of fines and penalties, and seek opportunities for settlement agreements.

2. Consultations on the settlement of tax debts

We determine the actual amount of debt and identify possible errors in calculations on the part of the IRS. We prepare arguments for reconsideration or cancellation of part of the debts. Our IRS attorneys can arrange alternative repayment plans: Installment Agreement (payment plan to reduce financial burden) or Offer in Compromise (agreement for partial debt payment upon proving inability to pay in full). We represent clients’ interests in cases of account freezes and wage garnishments.

3. Strategic Client Protection

Our team of IRS attorneys ensures the development of a long-term strategy that includes both pre-trial negotiations and potential litigation. We take into account the specifics of the industry, the client’s financial situation, and business development prospects. We assist in complying with FATCA, FBAR, and other international transparency standards in tax law. We guarantee complete confidentiality in all aspects of the case, minimization of reputational risks, and maintaining a high level of business reputation.

If you are facing IRS audits, debt collections, accusations of tax evasion, or other difficulties in dealing with the Internal Revenue Service — do not postpone resolving the issue. Contact us for professional legal assistance. Our team Interpol lawyers Ready to take your situation under control, propose optimal ways out of the crisis, and ensure maximum protection of rights and interests. Contact us, to schedule a consultation and take the first step toward effective dispute resolution with the IRS.

Interpol Lawyer Dmytro Konovalenko
Dmytro Konovalenko
Senior Partner, Attorney-at-law, admitted to the Bar (Certificate to practice Law #001156)
Lawyer specializing in extradition and Interpol cases, with membership in the International Bar Association. In five years of practice, Dmitry has defended clients against persecution by law enforcement agencies in the United States, Russia, Uzbekistan, Ukraine, Russia and other countries. He has successfully applied measures to prevent a manhunt at early stages and specializes in defending in complex cases involving economic, political and military charges.
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