UK US Tax provides a number of different types of representation services to clients, including assistance with past-due returns, with collection matters and with IRS audits. The nature of these services is summarized below.
Past Due Returns. UK US Tax regularly assists clients who have many years of delinquent filing obligations. Some of these have been sufficiently serious to advise making an affirmative approach to the IRS in a voluntary disclosure situation in an effort to obtain IRS assurances (in accordance with administrative guidelines) that no criminal prosecutions will take place. Other delinquencies are less serious and merely require filing delinquent returns and paying back taxes, interest and, occasionally, penalties. Not only have we often been able to reduce or eliminate any delinquency penalties, but we also have worked out payment plans where the back taxes and interest can be paid over a period of years.
Collection Matters. UK US Tax also deals with IRS Revenue Officers who are charged with collecting previously assessed taxes. We have worked out installment plans in such circumstances and, where warranted, we have had the IRS reduce the amount they were due in exchange for a lump sum payment.
Audit Services. Increasingly, the IRS has focused on non-resident U.S. taxpayers and has begun auditing foreign tax credit claims and other aspects of these person’s returns. The partners at UK US Tax have a long history of representing clients in audit situations. This representation includes all aspects of the audit procedure, including responding to initial inquiries, document requests and meetings with IRS examination officers. UK US Tax is well placed to handle such audits. Not only do the partners have a combined experience of over forty years in dealing with IRS audits, but also its partners are resident in both the United States and United Kingdom. This ensures the ability to meet locally with European based clients as well as the ability to meet with U.S. based IRS examination agents handling the audit.
In addition, one of the UK US Tax partners is a tax lawyer and although UK US Tax does not provide legal representation, it can work through Kovel type arrangements to ensure to the maximum extent possible that confidentiality is maintained throughout the audit process. This confidentiality allows for a much freer discussion of the issues underlying an audit, ensuring that a more realistic evaluation of the issues can take place at the outset of an audit with all the benefits resulting there from.
UK US Tax has also represented clients before the IRS Appeals Office, a separate division of the IRS designed to settle cases that are unresolved at the IRS Examination Office. We have often resolved cases at Appeals where the Appeals Office has dropped issues raised by the IRS Examination Officer and on other occasions we have settled disputes at levels favorable to the taxpayer while avoiding the costs and risks associated with litigation.