FEDERAL TAX SERVICES
WKBK&Y’s Federal Tax Services assists clients with tax planning and compliance not limited to business entities. Our tax attorneys counsel on tax planning, taking into consideration client needs, legal uncertainties and client comfort in taking tax positions.
As a leading Northern California tax firm, our attorneys hold a wealth of knowledge and experience in Federal income taxation. We have actively assisted in tax audit examinations, tax settlements, tax appeals and representation on tax issues before the U.S. Tax Court, District Courts and the US Bankruptcy Court. Our firm follows Circular 230, which sets out the requirements for tax practitioner standards and services.
Our services range from basic tax advice regarding home ownership to tax assistance for major business transactions. In Northern California, our tax attorneys are sought to advise on issues particular to the community, including the tax consequences from economic changes, both good and bad. In fact, we are often called upon by CPAs and other professionals to assist their clients with their issues.
FEDERAL TAX SERVICE AREAS
PURCHASES, INVESTMENTS, AND DEBT
Because our tax expertise is so comprehensive, it is impossible to describe all of the tax areas that we serve. Our lawyers assist with all tax issues involving purchases, investments and debt. We also provide further assistance with:
- Accounting method/period changes
- Tax deferral for condemnations
- Installment reporting requirements
- Gain characterization for favored tax treatment
- Donation deduction planning
- Tax-deferred (Section 1031) exchange qualification
- Tax consequences of debt discharge (CODI), including disputed debt exclusion, real property business indebtedness exclusion, insolvency and bankruptcy
- Tax deferred involuntary conversion, condemnation exclusion (Section 1033)
WKBK&Y has advised on numerous other technical tax issues. Whether it is inventory capitalization (Section 263A), benefit recoveries, tax credits, tax characterization of debt verses equity, a valuation issue for tax purposes, a stock option or defending against a tax shelter claim by the IRS or FTB, WKBK&Y’s lawyers can help.
EMPLOYEE BENEFIT PLANS
We advise on employee benefit plans, including:
- ERISA/DOL compliance, including voluntary and involuntary compliance
- Incentive stock options and nonqualified stock options.
- 409A deferred compensation requirements
- Insurance based benefits, including key-man insurance and split-dollar insurance.
- gain characterization for favored tax treatment
FEDERAL TAX ADVOCATE
We are also an advocate in many areas. This includes penalty abatement requests, intermediate sanctions, amnesty programs and voluntary compliance program requirements. Our firm has represented taxpayers before federal tax audits, protest appeals, Tax Court matters, federal district court actions and collection matters. Other tax representation areas include:
- Worker Classification (employee or independent contractor)
- Payroll Penalties (including EFTPS)
- Transferee Liability; Responsible Party Liability
- Information Reporting Duties
- Tax Practitioner Representation
- Failure to File Status
- Summons Defense
- Voluntary Disclosure Programs
- Amnesty Requests
- Offers in Compromise
- Installment Agreements
- Innocent Spouse Applications
- Lien, Levy & Garnishment Defense
- Statutory Notice of Deficiency
- Negligence and Fraud Penalty
- Seizure and Jeopardy Defense
- Private Letter Ruling Requests
- Advisory Services Incident to Divorce or Bankruptcy
- Opinions of Counsel
- Tax Violations of U.S. Bankruptcy and Securities Laws
- Reporting Off-Shore Accounts
- FBAR Returns and PFIC Issues