Legal Services

Federal Tax & IRS Matters

Carrizo Global Law provides attorney-led counsel and representation to individuals and businesses in federal tax matters and matters involving the Internal Revenue Service.

Our practice includes federal tax analysis and planning, entity tax classification and elections, tax considerations arising from business transactions and ownership structures, IRS notices and examinations, collection matters, and federal tax controversies.

When a federal tax issue intersects with business structure, immigration, District of Columbia trusts and estates, or cross-border activity, we also evaluate whether those legal considerations should be coordinated as part of the broader strategy.

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How We Approach Federal Tax Matters

Federal tax matters are highly dependent on the taxpayer's circumstances, filing history, entity structure, transaction history, procedural posture, and the particular provisions of federal tax law involved.

We begin by identifying the tax issue, understanding the relevant facts and documents, and determining whether the matter requires planning, compliance analysis, corrective action, or representation before the Internal Revenue Service.

Depending on the matter, our analysis may consider:

  • Taxpayer and entity classification

  • Filing and compliance history

  • Business ownership and organizational structure

  • Federal tax elections

  • Transaction timing and tax consequences

  • IRS notices, deadlines, and procedural posture

  • Penalties, interest, or collection exposure

  • Available administrative remedies

  • International or cross-border federal tax considerations

  • Whether business, immigration, D.C. trusts and estates, or other legal issues materially affect the matter

The objective is to provide legally grounded federal tax guidance appropriate to the client's particular circumstances.

Federal Tax & IRS Matters We Handle

  • Carrizo Global Law advises individuals on federal tax matters involving filing obligations, prior-year compliance, changes in personal or financial circumstances, corrective action, and interactions with the Internal Revenue Service.

    Representative matters may include:

    • Federal income tax filing and compliance issues

    • Review of prior filing positions and federal tax history

    • Analysis and correction of prior federal filings, including amended returns where appropriate

    • Filing-status and dependency issues

    • Federal tax consequences of significant transactions

    • Estimated-tax, payment, and withholding considerations

    • Penalty and interest issues

    • Federal tax consequences associated with relocation or changes in residency

    • Federal tax issues involving self-employment or business ownership

    • Coordination of federal tax considerations arising from U.S. immigration, business ownership, or District of Columbia trusts and estates matters

    The appropriate federal tax treatment depends on the taxpayer’s particular facts, filing history, income sources, transactions, legal relationships, and the applicable provisions of federal tax law. Where a matter involves another practice area or jurisdiction, related legal issues may require coordinated analysis.

  • Carrizo Global Law advises businesses and their owners on federal tax matters arising from formation, operation, ownership, transactions, compliance, distributions, and changes in business structure.

    Representative matters may include:

    • Federal tax classification of LLCs, corporations, partnerships, and other business entities

    • Business federal tax filing and compliance issues

    • Partnership taxation and related owner-level federal tax considerations

    • C corporation and S corporation federal tax matters

    • S corporation election, eligibility, and reasonable-compensation considerations

    • Basis, capital contributions, distributions, and ownership-related federal tax consequences

    • Federal tax consequences of reorganizations, conversions, redemptions, or ownership changes

    • Corrective filings and prior-period federal tax compliance issues

    • Penalties involving business returns, elections, or federal information-reporting obligations

    • Coordination between business legal structure and federal tax classification or treatment

    A business entity’s legal classification under state law and its federal tax classification are not necessarily the same. Entity structure, ownership, elections, transactions, distributions, and compliance obligations should therefore be evaluated from both corporate-law and federal tax perspectives where appropriate.

  • Business transactions and changes in ownership, capitalization, or entity structure can create material federal tax consequences that should be evaluated before the transaction is documented or implemented.

    Representative matters may include:

    • Federal tax considerations in entity formation and capitalization

    • Contributions of property or capital to business entities

    • Admission, withdrawal, or changes in ownership interests

    • Membership-interest and stock purchases, sales, and transfers

    • Asset purchases and sales

    • Business acquisitions and dispositions

    • Internal reorganizations and entity restructurings

    • Holding-company, parent-subsidiary, and affiliated-entity structures

    • Distributions, redemptions, and owner buyouts

    • Business-succession transactions

    • Basis, gain or loss, and other federal tax consequences of transactions

    • Timing and sequencing of transactional steps

    • Coordination between transaction documents and business structure and the intended federal tax treatment

    Federal tax consequences should be evaluated before transaction documents are finalized or ownership and structural changes are implemented. The form, timing, sequence, consideration, ownership relationships, basis, and applicable federal tax provisions may materially affect the tax treatment and economic result of a transaction.

  • The legal form of a business under state law does not necessarily determine how the entity will be classified or taxed for federal tax purposes.

    Carrizo Global Law advises businesses and owners regarding federal entity classification and tax elections that may affect the taxation of the business and its owners.

    Representative matters may include:

    • Default federal tax classification of LLCs and other eligible entities

    • Disregarded-entity treatment

    • Partnership classification

    • C corporation tax treatment

    • S corporation elections and eligibility considerations

    • Federal entity-classification elections

    • Late-election relief or corrective federal tax elections where available

    • Changes in classification following ownership, organizational, or structural changes

    • Effective-date and eligibility considerations

    • Coordination of federal tax elections with business governance, ownership structure, payroll, compensation, and distributions

    Federal tax classification and elections can have continuing consequences for the entity and its owners. They should be evaluated in light of ownership, eligibility requirements, operations, compensation, distributions, compliance obligations, and the client’s broader business objectives before an election or classification change is implemented.

  • Carrizo Global Law represents individuals and businesses in federal tax examinations and related administrative disputes before the Internal Revenue Service.

    Representative matters may include:

    • Individual and business IRS examinations

    • IRS requests for records, documents, and information

    • Examination strategy, preparation, and procedural analysis

    • Review of proposed adjustments and examination findings

    • Representation in communications, conferences, and meetings with the IRS

    • Development, organization, and presentation of supporting evidence

    • Responses to proposed examination adjustments

    • Preparation of administrative protests challenging proposed adjustments

    • Representation before the IRS Independent Office of Appeals

    • Penalty disputes arising from examinations

    • Evaluation of administrative settlement and resolution options

    IRS examinations involve both substantive federal tax law and administrative procedure. Effective representation requires analysis of the asserted tax issues, development of the evidentiary record, preservation of procedural rights, attention to administrative deadlines, and evaluation of available opportunities to resolve disputed issues within the IRS administrative process.

  • U.S. federal tax obligations may follow individuals and businesses across borders and may depend on citizenship, federal tax residency, income sources, ownership structures, entity classification, and international transactions.

    Carrizo Global Law advises clients regarding U.S. federal tax considerations arising in internationally connected matters.

    Representative matters may include:

    • U.S. worldwide-income and foreign-source income considerations

    • Federal tax residency, substantial-presence, and residency-transition issues

    • Foreign income and foreign tax considerations

    • Foreign tax credit and foreign earned income exclusion considerations

    • U.S. persons holding ownership interests in foreign businesses

    • Foreign ownership of U.S. entities

    • Federal information-reporting obligations involving foreign ownership, foreign entities, or specified foreign assets

    • Transactions between U.S. and foreign related parties

    • U.S. business activities of foreign-owned entities

    • Federal tax consequences associated with immigration, expatriation, or international relocation

    • Coordination among federal tax, U.S. immigration, business and corporate, and District of Columbia trusts and estates considerations

    Cross-border federal tax matters may also implicate foreign tax law, U.S. state or local tax law, tax treaties, immigration law, corporate law, or other jurisdiction-specific requirements. Carrizo Global Law’s representation is limited to matters within the firm’s permitted scope of practice, with appropriately qualified U.S. or foreign counsel coordinated where another jurisdiction’s law requires additional representation.

  • An IRS notice does not necessarily mean that the Service’s position is correct, but it should not be ignored. The appropriate response depends on the type of notice, the underlying tax issue, the taxpayer’s filing history, the procedural posture, and any applicable deadline.

    Carrizo Global Law assists individuals and businesses with reviewing, analyzing, and responding to IRS notices and correspondence.

    Representative matters may include:

    • IRS balance-due and account notices

    • Penalty and interest notices

    • Underreporter and income-matching notices

    • Return-processing discrepancies and mathematical-error notices

    • Missing-return or filing-status inquiries

    • Proposed adjustments to reported income, deductions, credits, or tax

    • Federal information-return compliance notices

    • Requests for supporting information or documentation

    • Correspondence involving prior filings, amended returns, or corrective filings

    • Evaluation of response deadlines, supporting evidence, and available procedural options

    The first step is identifying what the IRS is asserting, the legal and factual basis for the notice, what deadline applies, and whether the appropriate response is to provide documentation, correct a filing, request reconsideration, dispute the proposed adjustment, or pursue another available administrative remedy.

  • When a federal tax liability cannot be paid immediately, the appropriate collection strategy depends on the amount owed, the taxpayer’s financial circumstances, compliance history, collection status, applicable deadlines, and the IRS procedures available in the particular matter.

    Representative matters may include:

    • IRS installment agreements and payment arrangements

    • Collection-related IRS notices and deadlines

    • Penalty-abatement requests and related administrative relief

    • Offers in compromise, where eligibility requirements are satisfied

    • Currently Not Collectible (CNC) status, where appropriate

    • Federal tax lien and levy matters

    • Collection Due Process and related administrative proceedings

    • Collection-statute and timing considerations

    • Resolution of balances involving multiple tax periods

    • Compliance requirements necessary to obtain or maintain collection relief

    • Evaluation and comparison of available IRS collection alternatives

    IRS collection alternatives are not interchangeable. Eligibility, financial disclosure requirements, continuing compliance obligations, collection deadlines, and the consequences of each available option should be evaluated before a taxpayer commits to a particular resolution strategy.

These categories are representative and are not an exhaustive description of the firm's Federal Tax & IRS practice. The availability and scope of representation depend on the nature of the matter, applicable federal tax law, procedural posture, and other relevant legal considerations.

When Federal Tax Intersects With Other Legal Matters

Federal tax issues do not always exist in isolation.

Business formation, ownership changes, transactions, immigration or residency decisions, estate planning, and cross-border activity can all create federal tax considerations.

When those issues materially intersect, Carrizo Global Law evaluates the relevant legal relationships and determines whether coordinated analysis across practice areas is appropriate.

Where a matter implicates state, local, or foreign tax law or another jurisdiction’s law additional analysis or coordination with appropriately qualified counsel or tax professionals may be required.

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Discuss Your Federal Tax Matter

Federal tax issues can involve significant legal, financial, and procedural consequences, and the appropriate strategy depends on the particular facts and stage of the matter.

Request a consultation with Carrizo Global Law to tell us about your federal tax or IRS issue and determine the appropriate next step.

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