IRS, Federal Grand Jury And State Tax Defense Services
If you are an individual, a company, a business or any other entity facing or expecting to face a civil or criminal tax investigation, you should immediately seek assistance from a skilled tax lawyer.
At the office of attorney Michael S. Adelman, you will find an unparalleled level of experience. For 16 years, Mr. Adelman was employed in the IRS Office of Regional Counsel in Philadelphia. In this role, he evaluated criminal tax matters and represented the IRS in civil audit appeal cases in United States Tax Court involving issues such as unreported income, misstated deductions, civil fraud and/or other penalties or innocent spouse relief.
Since the mid-1980s, Mr. Adelman has been in private law practice offering tax defense services that range from full-scale legal representation to consulting and counseling, serving as co-counsel or as an expert witness.
Recap of this experience: More than 50 years as a tax controversy attorney on both “sides.”
Offshore and Foreign Account and Asset Compliance Options
Mr. Adelman has assisted many clients successfully through three rounds of IRS foreign offshore account amnesty programs. In 2014, the IRS modified the program to include Streamlined Filing Compliance Procedures (SFCP) that is beneficial for certain clients. However in 2018 the IRS ended its OVDP options. My clients in most cases still have the option to attempt to get into full compliance under Streamlined Filing Compliance Procedures (SFCP).
If undisclosed offshore accounts are an issue,
- 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, the SFCP remains a great opportunity.