International Tax:  Advice and planning on matters relating to the taxation of international transactions, operations, and investments and transfer pricing, including tax-efficient structuring of cross-border investments and transactions, as well as optimum use of tax treaties, foreign tax credits, tax deferral, and entity classification.

 

Tax Controversy: Representation before the Internal Revenue Service with respect to correspondence, office, field and TCMP audits and their appeal. Representation before the Michigan Department of Treasury with respect to income, sales, use, withholding, single business tax, corporate income tax and personal liability assessments. Tax collection matters including full payment assistance, currently not collectible request,  installment agreement request, offer in compromise request, tax driven bankruptcy, tax levy relief, tax lien relief, penalty abatement request, innocent spouse relief, refund claim request, collection due process and equivalent hearings, revenue officer representation, trust fund recovery penalty representation, and administrative appeals representation.

Tax Litigation: Federal tax litigation in the U.S. Tax Court, federal district courts, federal circuit courts of appeal, and the U.S. Court of Claims. State tax litigation in the Michigan Tax Tribunal, circuit courts and the court of claims.

 

Tax Crimes:  Represent clients in criminal tax matters, grand jury investigations, failure to file, tax evasion, failure to pay, misrepresentation, false statement, aiding and abetting, and voluntary disclosure including OVDI (offshore voluntary disclosure initiative). Foreign bank account report (FBAR) analysis and compliance.

 

Employee Benefits:  Advice and planning to employers and plan service providers in the following areas: design and administration of qualified plans, legislative and regulatory changes, representation before the Internal Revenue Service, compliance with Title I of ERISA, executive compensation, health and welfare benefits, tax-exempt and governmental employer representation and employee benefits dispute resolution.