Defense Strategies After Tax Reform
Generally speaking, the massive tax law changes emanating from the passage of the Tax Cuts and Jobs Act (TCJA) of 2017, do not impact (m)any of the issues, personalized strategies or procedures arising in my Tax Defense practice.
Inaccurate and/or unfiled tax returns must still be brought into compliance whether identified as part of a criminal investigation, tax audit, IRS Enforced Collection matter or otherwise. Unpaid taxes if subject to enforced or other IRS Collection efforts must still be properly addressed in a very fact-specific way, utilizing all available IRS Collection Appeal options.
Offshore Account Compliance
And Foreign Account Compliance via FBARs, amended tax returns and/or related FATCA documents is more vital than ever, with remedies, including the possibility of implementing the very favorable Streamlined Procedures (SDOP) component of the Internal Revenue Services’ OVDP (Offshore Voluntary Disclosure Program). Mr. Adelman’s nearly five decades of tax controversy experience is essential in this sometimes sensitive disclosure process.
Little is expected to change because of TCJA in IRS criminal tax investigations, Federal Grand Jury, FBAR/OVDP, money laundering or IRS collection tax controversy matters. These are the matters which tax attorney Michael S. Adelman has been resolving for almost five decades.