Tax Problems Don't Solve Themselves

The best time to contact our firm is when you’re first notified by an auditor of the California Department of Tax and Fee Administration (CDTFA) that he or she wants to schedule a sales tax audit. We specialize in controlling the audit from day one. We will assist you with a pre-audit of your business records, setting the boundaries of the audit with the auditor, making sure that the sampling of invoices is fair and restricted in scope to relevant items. We will also research the law, regulations and annotations that pertain to your particular business. As part of our representation, we will file a Petition for Redetermination or refund claim, settlement proposal, offer in compromise or installment agreement request, as necessary and advocate on your behalf throughout the entire audit and appeals process. As the former Deputy State Controller-Taxation, I sat on the California Board of Equalization (BOE) from 1995-98 and heard thousands of sales and use tax appeals.

We will begin by educating you about the audit and appeals process; and, then seek to gain a full understanding of the facts, issues and the law that are applicable to your tax controversy. We specialize in audit negotiation, dealing with Collections, removal of liens on your property, levies of your bank accounts and garnishments of your wages, settlement offers, offers in compromise, installment agreements, appeals to the IRS Appeals Office and the U.S. Tax Court.

When the Franchise Tax Board (FTB) contacts you to schedule an audit most taxpayers are completely unprepared for what lies ahead. We can assist you. First, we will educate you about the audit, protest and appeals process; and, then seek to gain a full understanding of the issues and the law that is applicable. We specialize in income and franchise tax audits, protests, appeals, residency audits, voluntary disclosures, removal of liens, levies and garnishments, settlements, offers in compromise, installment agreements, negotiations with the FTB and arguing before its appellate body, the Office of Tax Appeals (OTA).

Generally speaking, most of our clients with payroll tax or employment tax problems are the result of business owners borrowing taxes to pay current expenses, or hiring an inept payroll clerk or a business downturn; so we see our fair share of penalty cases. The Employment Development Department (EDD) and the IRS automatically impose penalties for the slightest of errors in reporting and payment of payroll taxes. Occasionally these penalties can be abated or waived, but the arguments must persuade the IRS or EDD that “reasonable cause exists”. That is where we can help.

Learn more about Payroll Tax Audits and Appeals​

We offer consulting and transactional advice on all aspects of state and local tax matters, including sales and use, franchise, income, property, fuel, payroll (employment) and business license tax issues.

We can assist you with state and local tax planning and transactional advice relating to acquisitions, mergers, reorganizations, worldwide unitary combination, divestments, relocations, credits, nexus, sale and leasebacks of major buildings, leasing of equipment, asset sales, employee compensation and benefits, residency, employee versus independent contractor and company acquisitions.

Income taxes in California can be imposed in several different ways depending on the source of the income and the residency status of the resident. Residents are subject to income tax upon their entire taxable income, whereas part-year residents and nonresidents are only subject to income tax on income derived from sources in California. 

Our firm is experienced in these types of issues and the common pitfalls associated with switching residency from state to state. ​

Learn more about Domicile and Residency Issues

If you find yourself in a situation where you’re unable to pay an outstanding tax liability you may be able to take advantage of programs offered by the IRS, FTB, CDTFA and EDD to get assistance. While an outright reduction is obviously the best outcome, not all taxpayers will qualify. If you don’t qualify for a reduction of tax, interest and penalties, you may want to consider a settlement, offer-in-compromise (OIC) or payment plan (installment agreement).

Dealing with worker classification issues can be tricky and the tax implications of doing it incorrectly can be significant. Since the IRS and EDD prefer to collect tax revenues early on they have a bias toward classifying all workers as employees if there is any question. Obviously, this can create issues for employers who classify workers as independent contractors.

Learn more about how to differentiate between employees and independent contractors​ and what to do if you find yourself with a worker classification issue.

For the individual taxpayer, a property tax appeal is a daunting task but it is actually quite simple so long as you are able to gather relevant evidence of your home being over assessed as compared to your neighbors. As for businesses, an assessment appeal can be an arduous process as the assessors do not want to relinquish control of tax dollars and will fight to hold onto every cent. Accordingly, an appeal can take years. To successfully appeal your property tax assessment, you need someone who has done hundreds of appeals. That’s us.

Learn more about Property Tax Assessment Appeals​

We are experienced at drafting tax initiatives, organizing initiative committees, gathering signatures, polling, running initiative campaigns and qualifying your pro-business tax initiative for the ballot. We also draft statutes, regulations, or annotations for our clients that desire to see a change in the current rules for one reason or another. Once drafted, we shepherd these revisions through the various legislative or regulatory committees.