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 liability law and IRS requirements can lead to serious liability, significant fines, account freezes, audits, and legal proceedings that hinder the company’s growth and undermine its reputation.

If your business is facing a tax problem, an audit, claims, or an investigation from the IRS, contact our IRS tax attorneys. Our attorneys will protect your company’s interests, eliminate any tax liability, and the risk of significant penalties, and ensure your firm in 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 the Internal Revenue Code, administering tax laws, and collecting taxes within the United States. The organization monitors compliance with the Internal Revenue Code, oversees audits to ensure the accuracy of calculations and the 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 Internal Revenue Code and the service’s work determines the funding of government programs (security, healthcare, social security, etc.). The service also audits and monitors those audits for 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 the property, garnish income, take employment taxes, and take other measures to collect debts. That is why it is extremely important to consult with a top tax attorney, law firm, or specialist and make timely adjustments to tax planning and business processes.

When do you need a lawyer for IRS tax cases?

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

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 process, IRS employees identify discrepancies or suspect underreporting of income, they may assess or say taxpayers owe additional taxes and penalties. An IRS lawyer will evaluate the validity of the audits and claims, have taxpayers challenge the audit results if necessary, and make the taxpayers make every effort to have taxpayers 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 tax resolution, 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 tax law specialist and tax attorney 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 free 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 audits

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 client’s 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 circumstances and 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 to reach a settlement agreement and ensure 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 an experienced tax attorney or IRS attorney. Specialists in tax law will help develop a reliable defense strategy, negotiate with the IRS, and, if necessary, represent your interests in court.

IRS Tax Issues

Audits and investigations by the IRS audits

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 process of IRS audits can be triggered by dissatisfied clients, partners, or employees who have filed a complaint with the regulator. If companies, clients or individuals repeatedly submit incomplete or incorrect returns, the risk of an in-depth audit process increases.

In the case of detecting underpayment of employment taxes, 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 assists a tax attorney in organizing financial reports, contracts, and bank statements. An IRS lawyer can present compelling evidence and challenge unjustified charges or procedural violations. In cases of serious disputes with audit results, a complaint can be filed with the IRS Appeals Division or taken to a tax court for resolution.

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 promptly; 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 and tax liability remains.

A qualified tax attorney will assess the client’s ability to repay the debt and prepare evidence for the IRS. If the IRS claims or imposed penalties are based on incorrect information, the most competent representation of an experienced tax attorney will be able to challenge them. An experienced specialist tax resolution and tax attorney will do tax planning and 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 and improper inflation of expenses and deductions. Falsification of financial statements includes underreporting revenue, fictitious transactions, and double bookkeeping.

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

The attorney reviews all materials collected by a law firm, the IRS, and the prosecutor’s office, and 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 from taxpayers in several legal ways. Garnishment (withholding from wages) – the person, business, employer or firm you owe to receives an order to deduct money from wages until the debt is paid off. Levy (seizure of bank accounts) – the bank or firm you owe to is required to freeze or withdraw funds from the taxpayer or firm‘s account in favor of the IRS.

Withholding can reach a significant portion of income, up to the deprivation of means of subsistence. Account and fees and seizures make many of the person or 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

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

The IRS has the right to seize movable and immovable property to get the money you owe or to cover debts you owe it if voluntary payment of back taxes has not been made. The seizure may extend to bank accounts, brokerage assets, businesses, and other sources of income that taxpayers have.

To dispute or prevent such a decision, it is necessary to check whether notifications were sent on schedule and whether the taxpayer’s expectations regarding response deadlines and expectations 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 a tax attorney, law firm, and business reputation. Effective protection of interests requires an experienced tax attorney with a comprehensive approach to tax problems and a deep understanding of American tax law. Our law firm provides professional support at all stages of interaction with clients and the IRS: from audits to litigation.

1. Defense in tax court disputes and representation before the tax court IRS

Our experienced specialists and attorneys 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 the tax administration office, authorities, and attorneys. We handle the preparation of objections and appeals in case of disagreement with tax administration or additional charges, negotiate the reduction of fines, fees, and penalties in tax controversies, 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 many taxpayers) 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 and tax 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. We also offer IRS payroll tax help that includes assisting individuals who are the target of the Trust Fund Recovery Penalty concerning payroll taxes owed.

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 of Interpol lawyers is Ready to take your tax situation back under control, propose optimal ways out of the crisis, and ensure maximum protection of rights and interests. Contact us, to schedule a free 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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