If you are an individual, a company, a business or any other entity facing or expecting to face a criminal or civil tax investigation, you should immediately contact Michael S. Adelman, Esquire.
- From 1970 through mid-1986, Mr. Adelman was employed in the IRS' Office of Regional Counsel in Philadelphia, serving as a senior trial attorney from 1975 to 1986.
- During this 16-year service as an IRS attorney, Mr. Adelman was a specialist in the evaluation of criminal tax matters (tax evasion, false returns, nonfiling and federal grand jury cases). For seven of those years, he also represented the IRS in United States Tax Court civil cases arising from appealed tax audits, usually involving issues such as unreported income, misstated deductions, civil fraud and/or other penalties, innocent spouse relief, tax shelters or transferee liability.
- From mid-1986 to date, Mr. Adelman has counseled the other side, with a legal practice geared exclusively to tax defense. His services range from full-scale legal representation to consulting and counseling, serving as co-counsel or as an expert witness.
- Recap: Well over 46 years as a Tax Controversy Attorney on both "sides"
A Third Offshore Account Voluntary Disclosure Opportunity — OVDP for 2012-2017
Mr. Adelman has assisted many clients successfully through the three IRS foreign account amnesty programs: the Offshore Voluntary Disclosure Program (OVDP) in 2009, the Offshore Voluntary Disclosure Initiative (OVDI) in 2011 and the still-open OVDP for 2012-2017. A major beneficial modification to the present OVDP, made by the IRS in mid-2014, is the possibly of qualifying for the Streamlined Filing Compliance Procedures.
Contact Mr. Adelman by calling 856-330-4035 to get in on the ground floor of this chance to avoid criminal prosecution and become current in all other respects.
- You will be helped to file amended tax returns, Report of Foreign Bank and Financial Accounts (FBARs) and Foreign Account Tax Compliance Act (FATCA) documents.
- To all owners/holders of offshore financial assets, there still has not been a final deadline imposed by the IRS for this OVDP. That may change without notice. This is a great opportunity. Contact Mr. Adelman now while your OVDP voluntary disclosure is still voluntary.