The best time to seek tax advice is when you are in the planning stages: before you buy or sell your company or move to the United States. However, if you are experiencing an audit by the IRS or California Franchise Tax Board, it is particularly critical to get professional help. If your audit concerns a complex financial transaction, you need advice from an adviser who understands the financial transaction and the applicable tax rules.
Jon has experience in the defense of complex financial transactions against the IRS and California Franchise Tax Board. Jon can also serve as special tax counsel in the context of arbitration and disputes between private parties disputing tax issues. Jon’s experience includes:
- Represented multiple taxpayers (recipients of earnout payments from a public company that acquired their company) in CA state tax audit on 453A interest charge in an installment sale.
- Counsel in CA state tax audit for taxpayer claiming bad business debt loss for loans to a controlled tech start-up.
- Advised owner of investment fund on complex tax issues in connection with arbitration over tax treatment of payment obligations to a retired partner.
- Represented multiple taxpayers in disclosing foreign assets and foreign bank accounts as part of the Offshore Voluntary Disclosure Program (OVDP).