Advise clients on the best course of action using insights from past cases.
Assess the accuracy of your characterization and calculate your risk.
Ensure your position is sound with an unbiased third-party report.
Can a taxpayer use the reasonable cause and good faith defense to avoid the accuracy-related penalty for an underpayment of tax pursuant to § 6662?
Is an interest in a corporation debt or equity for federal tax purposes?
Is a corporation a controlled foreign corporation or a passive investment foreign company for the purposes of the Internal Revenue Code?
Does a transaction have economic substance for tax purposes?
Is a worker an employee or an independent contractor for tax purposes?
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