IRS criminal tax matters, Tax Preparer Investigations, Offshore Voluntary Disclosure (OVDP) evaluations, civil audits, examinations and federal grand jury cases are Mr. Adelman's primary area of experience, practice and expertise. He has also become extensively involved in negotiations concerning:
- IRS offshore account, payment card and foreign entity inquiry letters and compliance efforts involving banks and foreign jurisdictions or other offshore financial arrangements allegedly for the purpose of avoiding or evading United States Tax obligations, as well as the use of allegedly abusive other tax shelters
- Tax professionals charged with violations of Treasury Department circular 230 "Practice Before the IRS"
- Significant developments regarding offshore accounts, Report of Foreign Bank and Financial Accounts (FBARs) and Form 8938
- Significant developments regarding offshore accounts, Determing Eligibility for Streamlined Procedures, Report of Foreign Bank and Financial Accounts (FBARs), the Foreign Account Tax Compliance Act (FATCA) and (most crucially) Intergovernmental Agreements (IGAs) and the crucial, constantly updated list of Foreign Facilitator Institutions (FFI) @IRS.gov. It is vital if a foreign institution you have been involved with is on the FFI List that you contact Mr. Adelman.
Defense For Federal Tax Crimes
A long-distance, mixed-media and/or in-person consultation can be arranged at a highly competitive fee. Consider contacting other attorneys of comparable experience first so you can establish the "market price" for such counseling. At the conclusion of this consultation, a cogent game plan and response will be recommended. Beyond the consultation, flexible arrangements based on the precise circumstances and your needs can be implemented. Rarely will you be rushed into payment of a large retainer. A step-by-step arrangement is usually feasible. In situations like these, a "one size" approach most certainly does not fit all.
Be sure to ask Mr. Adelman about his unique, written post-Consultation "TCA" Interim Retainer Agreement geared to clearly explaining all the terms of the Attorney/Client(s) Relationship in advance, for the benefit and protection of all parties.
Call lawyer Michael S. Adelman at 856-330-4035 or contact our office online today.