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U.S. Internal Revenue Service and State Audit and Controversy Services

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​​Every audit and tax controversy is unique and almost always inconvenient at best. We have significant experience in managing all types of audits and can assist you in resolving the issues as quickly and painlessly as possible. Specifically we can help with:  
  • Internal Revenue Service and State Income Tax Audits and Disputes
  • Other State Tax Audits such as Sales Tax or Property Tax Audits
  • Federal Voluntary Disclosures for Businesses
  • State Voluntary Disclosures/Amnesty Filings 
  • Federal and State Notice and Appeals Assistance 
  • Federal and State Refund Claims
  • Federal Individual Taxpayer Voluntary Disclosure Options

 

For individual taxpayers who have failed to file prior year Federal Individual Income Tax Returns, there are voluntary disclosure procedures that might be available to allow them to get into Federal income tax compliance by voluntarily filing tax returns/forms for a prescribed number of years. These procedures generally help the taxpayer to reduce or completely avoid the possible penalties for late filing. One of the primary voluntary disclosure procedures, the Offshore Voluntary Disclosure Procedures, has recently expired; however, the procedures listed below are still available:   

 

Streamline Filing Compliance Procedures – These voluntary disclosure procedures allow certain individuals residing inside or outside the U.S. whose lack of timely filing was non-willful to generally file/pay three years of delinquent income tax returns and six years of FBAR forms to get into compliance with Federal income tax requirements. For those individuals living inside the U.S. who qualify for these procedures, penalties for failure to file/pay tax are significantly reduced. For those individuals living outside the U.S. who qualify for these procedures, penalties for failure to file/pay tax are generally waived.

 

Delinquent FBAR Submission Procedures – For certain qualifying taxpayers who need to file delinquent FBAR reports but do not need to file delinquent income tax returns under the Streamline Filing Compliance Procedures, these procedures might allow the taxpayer to avoid late filing of FBAR penalties.

 

Delinquent International Information Return Submission Procedures – For certain qualifying taxpayers who need to file various international forms (e.g. Forms 5471, 5472, 8938, etc.) but do not need to file under the Streamline Filing Compliance Procedures, these procedures might allow the taxpayer to avoid late filing penalties. For more information please see Rödl Tax Matters.

Contact

Elisa Fay

CPA

Partner-in-Charge Rödl National Tax

+1 404 525 2600

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