Solving Complex Tax Disputes

Sharp Partners P.A., has more than 25 years of experience resolving international tax controversies. Our attorneys represent U.S. and foreign clients in all facets of civil and criminal tax controversies from initial audits through administrative appeals proceedings and judicial and appellate proceedings.

Civil Tax Proceedings

During the initial examination phase of an IRS audit, our attorneys will work closely with the client and the client's certified public accountants and interact with the IRS auditors to progress the audit. We will monitor the development of the examination's factual record, and craft an overall case strategy. During the audit, we will provide advice on a wide range of issues, including responding to information document requests, controlling statutes of limitation, identifying and protecting privileged documents and responding to audit adjustments.

If the tax audit cannot be resolved at the examination level, we will proceed to the administrative programs and procedures that best may facilitate a resolution of the case, including resolution through a treaty mutual agreement procedure.

We always strive to resolve controversies in a timely manner and to reach favorable outcomes through settlement negotiations with the IRS. However, in some cases, it is in our client's best interest to litigate a tax controversy. We have the experience and proven trial strategies to represent clients in these situations as well. Our experienced litigators consider resolution through tax litigation in the United States Tax Court, United States Court of Federal Claims, the United States District Courts and the United States Courts of Appeals.

Criminal Tax Proceedings

Federal criminal tax related investigations and prosecutions under Title 26, United States Code, are particularly hazardous as they create both serious financial exposure and incarceration exposure. While such prosecutions are commonly based upon a U.S. taxpayer's failure to report income, often present are related factors that can give rise to even more severe penalties under Title 18, United States Code. For example, if the unreported income was not lawfully sourced, potential money laundering, or similar charges may be implicated as well, with elevated levels of incarceration exposure.

Accordingly, when one has reason to believe that he or she may be the target of an IRS criminal tax proceeding, it is important to immediately retain experienced white-collar criminal defense counsel. The sooner white-collar counsel is engaged, the more he or she can do to achieve the best result for the client.

Criminal defense counsel not only helps you to fully understand what you are facing, but acts as a "buffer" between you and the authorities, protecting your rights at each stage of the process. Experienced counsel will advise on the best course of action to either minimize exposure or avoid it entirely.

We have decades of in-depth experience in working with white collar defense counsel to defend clients in all phases of tax-related criminal investigations and prosecutions.

Civil and Criminal Tax Proceedings Experience

Our team of experienced international tax attorney can assist with all aspects of civil and criminal tax proceeding. From our offices in Tampa, Florida; San Francisco, California; Washington, D.C and Zurich, Switzerland, we are able to assist clients worldwide.