Texas Business Tax Matters
Employers and business owners throughout the U.S. and North America, as well as international and multinational business owners, rely on the knowledge and experience of Texas business tax attorney Lawrence Brown.
Brown, PC, is able to provide experienced representation to businesses and individuals across a great variety of tax controversies and tax litigation matters involving business tax and employment taxes such as the following:
- Worker classification disputes related to independent contractors versus employee designations.
- Trust Fund Recovery penalties and other types of payroll tax issues, including those related to the use of a professional employment organization (PEO)
- Executive compensation, reimbursed expenses and fringe benefit issues
- State and local sales tax reporting and commercial property tax disputes
About Our Business Tax Practice
As a business owner or executive, making informed tax-related decisions is critical. This is true whether you are planning ahead, you need to rectify an oversight or mistake, or you are dealing with the Internal Revenue Service (IRS). Each Texas business tax attorney at Brown PC has extensive experience representing local, regional, national and international businesses with respect to:
Private Letter Rulings
Private Letter Rulings allow businesses to determine in advance whether the IRS is likely to challenge a particular tax position. Seeking out the IRS’s opinion when pursuing a complex transaction can be an effective means of risk management for all parties involved. However, securing the specific opinion you need can be challenging, so experienced legal representation is essential.
IRS Income Tax Audits
Our attorneys regularly represent businesses in Texas and elsewhere in complex IRS income tax audits. When facing a high-stakes audit, substantiation is key—and, if your company cannot produce adequate substantiation to justify the positions taken on its federal returns, then an alternate defense strategy will be required. If your company is facing an IRS income tax audit, our attorneys can help you make informed decisions while communicating with the IRS on your company’s behalf.
IRS Payroll Tax Audits
We also handle IRS payroll tax audits for our business tax clients. These audits have become more prevalent in recent years, and the IRS has shown increased willingness to pursue substantial penalties for all forms of payroll tax-related noncompliance. This includes not only penalties for companies, but also penalties for individuals who are involved in failing to properly account for employees’ payroll taxes or filing inaccurate returns.
Criminal Tax Investigations
Companies and individuals can face substantial exposure in criminal tax investigations as well. Our attorneys handle high-stakes investigations involving all types of criminal allegations, from knowingly implementing abusive tax shelters to willfully underreporting income and claiming fraudulent business deductions. If your company has received a subpoena or target letter from IRS Criminal Investigation (IRS CI), it is critical that you engage an experienced Texas business tax attorney promptly.
IRS Audit Appeals
If you disagree with the outcome of an IRS business tax audit, the next step in the process is to file an IRS audit appeal. In most cases, this involves going to the IRS’s Independent Office of Appeals, though businesses can challenge the IRS’s audit determinations directly in the U.S. Tax Court in some cases. Our attorneys have extensive experience handling complex appeals in both venues.
Civil and Criminal Business Tax Litigation
Along with IRS audit appeals, our attorneys have extensive experience handling virtually all other types of civil and criminal business tax litigation as well. If your company is unable to secure a favorable resolution at the audit or investigation stage, our team can provide effective representation in federal court. We have had significant success achieving favorable results for our clients both in pre-trial litigation proceedings and at trial.
International Tax Compliance
We are also able to help businesses in the U.S. and abroad with international tax compliance. Businesses that owe filing obligations to the IRS must report their worldwide income from all sources, and they must also disclose their offshore accounts and other foreign financial assets annually. A Texas business tax attorney at Brown PC can assist with meeting these requirements—and proving compliance with these requirements when necessary.
IRS Collection Actions (Liens, Levies and Seizures)
If your business is facing an IRS lien, levy or seizure, it is important that you take appropriate responsive action promptly. These collection actions can have devastating and far-reaching financial implications, and it is critical to defend against them to the fullest extent possible.
Offers in Compromise, Installment Agreements and Penalty Relief
Our attorneys are also able to assist companies with submitting offers in compromise, negotiating installment agreements and seeking penalty relief from the IRS when necessary. We can help you consider any viable alternatives as well, and we can develop and execute an approach to resolving your company’s federal tax debt that minimizes any ongoing risk and long-term obligations.
Voluntary Disclosures
If you have concerns about facing IRS scrutiny due to a business, corporate or partnership tax violation, submitting a voluntary disclosure to the IRS might be the best path forward. However, voluntary disclosures can be risky, and submitting a voluntary disclosure isn’t an option in all cases. We can help you make the right decisions.
Representative IRS Matters We Handle for Texas Businesses
Much of our practice is devoted to representing corporations, partnerships, owners and executives, and other business clients in complex IRS matters. Our team, led by founding attorney Lawrence Brown, has decades of experience helping clients avoid substantial tax liability and penalties in a wide range of federal tax controversies. Some examples of IRS matters we have recently been handling on behalf of our clients include:
- Abusive Tax Shelter Investigations
- Affordable Care Act (ACA) Investigations
- Employee Retention Credit (ERC) Investigations
- Paycheck Protection Program (PPP) Investigations
- Offshore Account and Foreign Financial Asset Disclosures
- Trust Fund Recovery Penalty Enforcement and Disputes
- Worker Classification Disputes and Other Payroll Tax Matters
Industries We Serve
Within our business tax practice, we serve clients in a wide range of industries. Over the years, we have been privileged to represent some of the largest companies and most successful business owners in the world. With this in mind, here is just a small sampling of the industries we serve:
- Advanced Manufacturing
- Aerospace, Aviation and Defense
- Arts, Entertainment and Professional Sports
- Maritime and Offshore Operations
- New Technologies
- Oil, Gas and Alternative Energy
- Professional Services
When Fast Action Is Required to Resolve Structural Tax Problems
Attorney Brown, a former Department of Justice Tax Division trial attorney, relates the following example of the types of complex cases he regularly handles on behalf of clients in the business and employment arena:
Case Study: Employment Tax Controversy
A local company with roughly 70 employees and total revenue of approximately $10 million had fallen behind in paying the federal taxes withheld from employee paychecks to the IRS. At the time we were hired, the total due to the federal government was well in excess of $1 million. IRS agents were within about 72 hours of shutting down the business.
Mr. Brown contacted the IRS group manager and requested that the IRS wait one week before shutting down the business. The request was granted. Our team worked nearly around the clock for approximately five days creating financial statements and financial models while working with the company CFO on overhead reduction. We proposed an installment agreement to the IRS that allowed the tax debt to be paid over a period of approximately 30 months and kept the company in business.
An Initial Consultation Is Only One Call Away With A Texas Business Tax Attorney
Call 888-870-0025 or email us to discuss your employment-related tax concerns with litigation lawyer Mr. Brown. Centrally located in Texas, our boutique law firm serves clients from across the U.S. and around the world.