Dist Case No. 5:14-cv-00830 (San Jose) – Client had received a $1 million tax bill from the IRS after having been unfairly denied access to participate in an IRS audit due to being in the hospital. Filed audit reconsideration and received 1/3 off tax bill in audit reconsideration. Appealed to the IRS appeals and received another 1/3 of the tax bill at the IRS appeals. The client paid tax and filed a refund litigation suit to recover the final 1/3. Case settled with client receiving nearly 100% refund on original bill.

[Tax Planning Client Not Public Record] – Advised client with worldwide operations on most tax-efficient structuring of business operations in different jurisdictions, taking into consideration line of business, type of income, related entity arms-length transactions, and maximizing tax deductions.

Dist Case No. 5:14-cv-00830 (San Jose) – Client had received a $1 million tax bill from the IRS after having been unfairly denied access to participate in an IRS audit due to being in the hospital. Filed audit reconsideration and received 1/3 off tax bill in audit reconsideration. Appealed to the IRS appeals and received another 1/3 of the tax bill at the IRS appeals. The client paid tax and filed a refund litigation suit to recover the final 1/3. Case settled with client receiving nearly 100% refund on original bill.

[Tax Planning Client Not Public Record] – Advised client with worldwide operations on most tax-efficient structuring of business operations in different jurisdictions, taking into consideration line of business, type of income, related entity arms-length transactions, and maximizing tax deductions.