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McMahon & Tivnan defends taxpayers in IRS examinations of their returns. The IRS selects returns for examination for a variety of reasons, but usually, there is some indication that IRS suspects represent a filing problem. Early intervention in an examination may prevent the matter from escalating and becoming a larger problem than it may have. Our tax audit attorneys in Montreal understand IRS examination techniques and can spot issues that may be problematic.
McMahon & Tivnan fights levies, liens, and seizures that IRS uses to collect unpaid tax liabilities. Our tax litigation attorneys serving Montreal offer many years of experience negotiating and litigating collection disputes with IRS enable us to reach the best payment terms possible and avoid involuntary seizure actions.
The best option for a client who cannot fully pay their tax liability is often an Offer in Compromise. Despite the message of frequent late-night TV commercials, an Offer in Compromise program is not for everyone and there are many requirements that must be met to reach an agreement with the IRS. Our Montreal tax attorneys can determine from an initial evaluation whether a client will qualify and what must be done to achieve success.
The IRS general Voluntary Disclosure program encourages taxpayers who become aware of a tax compliance problem to come forward by promising lenient treatment in exchange for coming forward and reporting a problem of which IRS was unaware. There is a special Offshore Voluntary Disclosure Program for reporting undisclosed offshore financial accounts. Consult with an IRS tax attorney in Montreal to learn more.
The IRS offers a quasi-independent review of IRS determinations before they become final, or a taxpayer is required to go to court. Many of our senior Montreal tax professionals either worked in or with the IRS Appeals Office when we were with the IRS. Our understanding of the rules and procedures of the IRS Appeals office enables us to achieve the best possible settlement offer from IRS before deciding if litigation is necessary.
Few firms can match the extensive tax litigation experience of McMahon & Tivnan. If a tax dispute cannot be resolved administratively, litigation becomes the only option. Our Montreal tax litigation attorneys’ extensive experience in the U.S. Tax Court and Federal District Courts on tax matters ensures the client’s interests are well represented.
Reporting of foreign financial accounts and assets is becoming the focus of more IRS scrutiny. Many tax attorneys in Montreal are either not familiar or comfortable with foreign asset reporting or knowledgeable about the possible problems of non-compliance. We work with clients to resolve past filing issues and ensure correct compliance going forward.
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Boston, Massachusetts 02110
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