Tax protection for businesses and owners
Tax Business Litigation: legal strategy for IRS notices, audits, penalties, collections, Tax Court, and the risk of personal liability for owners, officers, and managers.
In what cases is tax protection needed?
The main areas where tax issues most often become legal risks for businesses, owners, and managers.
Received an IRS notice or audit
A letter, audit, request for documents, or demand for explanations require a timely legal response.
The IRS requires taxes, penalties, or adjustments.
It is necessary to assess the validity of the claims and prepare a defense strategy.
There is a risk of collection or personal liability.
Tax claims can lead to asset seizure or liability for the business owner.
There are international tax issues.
Foreign accounts, FBAR, overseas assets, or international reporting require a separate risk assessment.
Tax planning and protection before the IRS
Before receiving a tax claim, the focus is on tax planning and risk reduction. After receiving the claim, the key task becomes protecting the client's interests and resolving the tax dispute.
Цель — предотвратить проблему
Before receiving a tax claim
- Tax risk analysis
- Tax planning
- Choosing the optimal business structure
- Structuring transactions
- Document preparation
- Reviewing tax returns before submission
- Consultations before the transaction
- Minimizing tax burden through legal means
- Audit prevention
- Dispute prevention
- Legal support for businesses
- Legal prevention
Цель — решить уже возникшую проблему
After receiving a tax claim
- IRS claim analysis
- Defense strategy development
- Legitimacy verification of claims
- Evidence collection
- Preparation of official response
- Correction of errors in previously filed returns
- Post-transaction defense
- Minimization of penalties, interest, and assessments
- Tax audit support
- Dispute resolution
- Representation before the IRS
- Negotiations and appeals
What is important to do before responding to a tax claim
A comprehensive legal analysis allows for the assessment of risks and the selection of an effective defense strategy.
01
Analysis of the legality of the tax claim
We check the compliance of the claim with legal requirements; assess the authority of the IRS; analyze the deadlines for filing claims; identify potential procedural violations.
02
Determining the causes of a tax dispute
We establish the reasons for the claim; analyze tax reporting; check financial transactions, income, deals, business activities, and other circumstances of the case.
03
Review of documents and evidence
We analyze tax returns, bank statements, accounting and corporate documents; review correspondence with the IRS; and establish a foundation for further defense.
04
Assessment of legal and financial risks
We determine the potential amount of additional charges, penalties, and interest; assess the likelihood of a tax audit, asset recovery, and the impact of the dispute on the business.
05
Formation of a protection strategy
We develop the most effective protection strategy; assess the prospects for appeal; prepare recommendations for further actions and possible settlement options.
06
Preparing for Interaction with the IRS
We determine the order of further actions; prepare the necessary documents and evidence; develop a legal position to protect the client's interests before the IRS.
How Grant Law can help
Grant Law Corporation can assist the client at every stage:
Preliminary analysis of the tax claim
Reviewing IRS notifications; assessing risk levels; explaining potential consequences.
Legal analysis of documents
We check declarations; analyze evidence; identify errors of the tax authority.
Development of a protection strategy
We determine the most advantageous position; assess the risks; prepare a plan for further actions.
Preparing the response
We prepare a legally sound response; we draft explanations; we gather supporting documents; we prepare attachments.
Negotiations with the IRS
Introducing the client: correspondence; phone negotiations; meetings; participation in the audit.
Appeal of decisions
If necessary: administrative appeals; settlement negotiations; preparation for litigation.
The process of protecting your interests before the IRS
From the analysis of the tax claim to the full resolution of the tax dispute
01
Analysis of tax claims and verification of requirements
Determining: what exactly is required by the IRS or tax authority; whether the claims made are justified; if there are errors in calculations or application of the law; what actions need to be taken within the specified deadlines.
02
Internal investigation and evidence collection
We analyze financial, tax, and corporate documents; review banking transactions, deals, and tax reports; identify circumstances relevant to the case; and build a reliable evidence base to protect your interests.
We create an evidence base to defend the client's interests.
03
Definitions of defense strategy
We formulate recommendations based on the circumstances of the case: fully contest the claim; partially acknowledge the demands; present additional evidence; correct the previously submitted declaration; seek the cancellation of fines; negotiate a settlement.
04
Preparation of the official response
The official response may include: legal position; references to tax legislation; references to case law; arguments against the IRS position; attachments and supporting documents.
05
Representation before the IRS
After submitting the official response, we continue to support the case until it is fully resolved: we conduct official correspondence with the IRS; respond to additional requests from tax authorities; represent the client's interests in negotiations and meetings; accompany the tax audit; monitor compliance with procedural deadlines.
06
Negotiating and protecting your interests
We negotiate with the IRS to achieve the most favorable resolution; we strive to reduce financial obligations and ease settlement terms; we assess potential legal and financial risks; we protect the client's assets, business, and property interests.
Frequently Asked Questions
What to do first when receiving an IRS notice?
Do not respond or sign anything until a legal assessment is made. Each notice has specific deadlines and procedural rights — these need to be checked before taking any action.
Are these accounting services?
No. Grant Law focuses on legal strategy and defense in tax disputes. Accounting, tax preparation, and CPA services are separate areas that are coordinated as needed.
When do you need a CPA, and when do you need a lawyer?
A CPA handles the preparation of tax returns and tax accounting. An attorney is needed when there is a dispute with the IRS, a threat of penalties, liens, levies, or personal liability — in other words, a legal conflict.
Civil tax fraud = criminal case?
No. Civil tax fraud is a civil matter with the IRS involving increased penalties. Criminal tax fraud is prosecuted by the DOJ. These are different processes, but both require a legal strategy from the very beginning.
Start with a legal risk assessment
Strategic consulting helps to identify where the legal weaknesses are, which documents need to be reviewed, and how to prepare for negotiations or a deal.