Overview
Ryan Tivnan is a Boston tax lawyer representing individuals, estates, and businesses in Civil Tax Controversy and Tax Litigation. He is a Senior Partner with experience investigating and defending IRS and state tax matters and excels at resolving difficult and complex tax disputes. He counsels clients through examinations and liability disputes and, when necessary, takes disputed issues to court.
Ryan also has extensive experience assisting individuals with foreign transaction reporting and penalty disputes, and voluntary disclosures and compliance, including foreign bank accounts and FBAR requirements.
Experience
Ryan counsels clients with federal and state tax controversies, including:
- Audits and examination, including calculation of correct tax liability, and minimizing penalties and interest
- Submissions of Offers in Compromise, Installment Agreements, and Innocent Spouse Relief to the IRS for settlement of tax liabilities
- Extensive experience assisting individuals and corporations with foreign bank accounts, FBAR, and Form 8938 reporting requirements in over 40 countries, including submissions to the Offshore Voluntary Disclosure Program, Streamlined Domestic and Foreign Procedures, and the additional disclosure programs
- Foreign bank account analysis, currency conversions, stock valuation, foreign tax credits and transactions, and calculations of capital gains and losses of assets, including cryptocurrency and PFICs
- Submissions of voluntary disclosures to the IRS to assist taxpayers with bringing their tax accounts into compliance
Previous Experience
Boston University School of Law (2016-2017)
- Teaching Assistant in Graduate Tax Program’s Practice and Procedures Course
Norfolk County Probate and Family Courthouse (2012)
- Legal Intern
- Researched and drafted motions and memoranda
- Analyzed estate assets