Tax

U.S. tax is not just math. It is policy, interpretation, and judgment—constantly evolving with legislative priorities, regulatory guidance, and global economic shifts. Recent developments such as the One Big Beautiful Bill underscore how quickly the tax landscape can change, and how critical it is to understand not only what the rules say, but why they exist and how they are applied in practice.

We believe sound tax outcomes come from understanding legislative intent, regulatory direction, and enforcement trends—not just technical rules. As tax laws continue to evolve, informed judgment matters as much as precision.

Our role is to help clients make thoughtful, defensible decisions—balancing compliance, risk, and opportunity—so they can move forward with clarity and confidence.

Our Tax Team partners closely with business owners, C-suite executives, and individuals to navigate this complexity with clarity and confidence. We do not take a one-size-fits-all approach. Instead, we focus on understanding your facts, your objectives, and your risk profile—then applying informed, defensible judgment to arrive at practical tax positions.

We can help:

  • Corporate Tax
  • Partnership Tax
  • Tax Due Diligence

International tax is not something you can outsource to software—or rely on AI to “figure out.”

The complexity lies not just in the rules, but in how countries apply them, how facts evolve, and how policy intent drives enforcement.

With deep experience across international tax matters, we provide forward-looking guidance on structuring, cross-border planning, global compliance, and reorganizations. We help clients anticipate regulatory change, weigh trade-offs, and make decisions that remain resilient as tax policies evolve.

Our goal is simple: you focus on driving growth—we manage the complexity and risk of your international tax compliance.

We can help:

  • Analysis of Tax Treaties
  • Choice of Entity
  • Foreign Investor’s U.S. Investment Planning
  • Foreign Tax Credit Analysis and Planning
  • Global Capital Structure Planning
  • Global Compliance
  • Going Overseas International Tax Planning
  • Information reporting and withholding tax planning and compliance
  • Minimizing GILTI and Subpart F Exposure
  • Passive Foreign Investment Corporation (PFIC) Reporting
  • Permanent Establishment Analysis
  • Transfer Pricing
  • Tax Residency Analysis

State and local tax has become one of the most aggressive areas of U.S. tax enforcement. As states seek new revenue, automated assessments, penalty notices, and broad nexus standards are now routine.

We help businesses and individuals navigate state income and sales tax obligations, evaluate multistate filing requirements, and respond to state notices before issues escalate. Our focus is practical: manage risk, defend reasonable positions, and avoid unnecessary surprises.

Why SALT is Painful

States increasingly issue the bill first and resolve disputes later.

Data matching, economic nexus rules, and automated systems mean compliance exposure can arise quickly—even when facts are incomplete.

Understanding where you have filing obligations, and documenting defensible positions upfront, is no longer optional—it’s essential.

We can help:

  • Income Tax Nexus Analysis
  • Multistate Income Tax Filing & Apportionment
  • State Registration & Voluntary Disclosure Agreements (VDAs)
  • Audit Defense & Notice Response
  • Penalty Abatement & Exposure Mitigation
  • State Tax Planning for Business Expansion
  • Remote Workforce & Economic Nexus Analysis
  • Entity Restructuring for State Tax Efficiency

Since the Wayfair decision, sales tax has become one of the most unforgiving areas of U.S. tax compliance. Economic nexus rules now trigger obligations without physical presence—and states are aggressively enforcing them.

Many businesses rely on automated tax software to “handle” sales tax, only to discover later that forms were missed, registrations were incomplete, or filings were technically incorrect. States do not excuse these errors. Missed or flawed filings often trigger automatic penalties, endless notice cycles, and interest that continues to accrue until the issue is fully resolved.

Sales tax enforcement is not about calculation—it is about timing, filings, registrations, and judgment. Software can calculate tax, but it does not assess risk, interpret notices, or stop penalties once they begin.

We help businesses identify exposure, file correctly, fix past issues, and shut down problems before they spiral. When it comes to sales tax, relying on automation alone is often how small issues turn into expensive ones.

We can help:

  • Sales Tax Nexus Analysis (Physical & Economic)
  • State and Local Sales Tax Registration
  • Sales and Use Tax Return Preparation & Filing
  • Marketplace Facilitator & Platform Analysis
  • Exemption Certificate Review & Management
  • Voluntary Disclosure Agreements (VDAs)
  • Sales Tax Audit Support & Notice Response
  • Penalty & Interest Mitigation
  • Remediation of Missed or Incorrect Filings
  • Ongoing Sales Tax Compliance Management

Payroll tax is not static – neither is your business.

“Set-and-forget” AI payroll systems assume stability—stable headcount, stable compensation, stable facts. That is not how real businesses operate.

For startups and middle-market companies, people join and leave, compensation changes, bonuses are issued, equity is granted, and roles evolve. Automated systems do not question assumptions, catch edge cases, or adjust when facts change. They process what they are given—and when something breaks, the consequences fall entirely on the taxpayer.

Payroll tax errors are among the fastest to escalate. Missed deposits, incorrect filings, or misclassified employees often trigger immediate notices, automatic penalties, and interest that continues to accrue until resolved. Once agencies issue assessments, fixing the problem becomes far more costly and time-consuming than addressing it upfront.

We use technology—but we do not rely on it blindly. Our payroll tax support emphasizes flexibility, human oversight, and active management. We help ensure payroll tax filings reflect reality, adapt as your business changes, and stay compliant before small issues turn into recurring enforcement problems.

You run a dynamic business. Your payroll tax compliance should be managed with the same level of attention—not left on autopilot.

We can help:

  • Federal, State, and Local Payroll Tax Compliance
  • Payroll Tax Registration & Account Setup
  • Payroll Tax Deposit Monitoring & Reconciliation
  • Quarterly Payroll Tax Filings (Forms 941, state equivalents)
  • Annual Payroll Tax Filings (Forms W-2, W-3, 940, state filings)
  • Multi-State Payroll Tax Compliance
  • Employee Classification Review (Employee vs. Contractor)
  • Payroll Tax Notice Response & Audit Support
  • Penalty & Interest Abatement
  • Remediation of Missed or Incorrect Payroll Filings

Tax controversy in the United States is rarely quick—and it is rarely simple. Resolution often takes time, persistence, and careful strategy.

Unlike systems where a tax filing is reviewed, approved, and closed, U.S. tax filings remain subject to review long after submission. Returns may sit in review queues for months—or longer—before issues surface. Silence does not mean closure. It often means waiting.

For international tax matters in particular, the risk is amplified. Many cross-border information returns carry automatic penalties if filings are late, incomplete, or technically incorrect. These penalties apply regardless of tax owed. In practice, they are frequently triggered by missed forms or technical errors—often because preparers were unfamiliar with the requirements. Once assessed, penalties can be difficult and time-consuming to reverse.

Tax controversy is not a one-size-fits-all exercise. Each case depends on facts, procedural posture, timing, and risk tolerance. What works in one situation may fail in another. Effective resolution requires understanding not only the law, but how the IRS applies it, how disputes progress, and where judgment calls matter most.

We assist clients throughout the controversy lifecycle—from responding to notices and examinations to penalty defense and negotiated resolutions. Our focus is to manage exposure thoughtfully, protect your position, and pursue outcomes that are practical, defensible, and aligned with your long-term interests.

We can help:

  • IRS & State Tax Notice Review and Response
  • Federal and State Tax Audits & Examinations
  • International Information Return Penalties
  • Penalty Abatement & Reasonable Cause Defense
  • Voluntary Disclosure & Compliance Remediation
  • Appeals Representation & Negotiated Settlements
  • Collection Matters (Liens, Levies, Installment Agreements)
  • Tax Payment Planning & Resolution Strategies
  • Cross-Border & Offshore Disclosure Matters
  • Litigation Support & Pre-Litigation Strategy