Associate | New Haven
Secretary Elizabeth O'Bryan
Offshore Voluntary Disclosure
Helped two sisters, both Offshore Voluntary Disclosure clients, facing a multimillion dollar (50%) penalty, to achieve a zero penalty result. They were thrilled, as the application of the 50% penalty would have decimated their retirement savings. They are now personal friends, and are enjoying their retirement in a warm, sunny local.
Reduction of tax assessment
Reduced a New York City tax assessment by 50% for a client, by putting forth several out-of-the box arguments for reducing this assessment.
Nonwillful filing errors
Helped numerous clients convey their nonwillful (accidental) filing errors to the IRS in a manner that resulted in a mere 5% penalty in Streamlined Domestic Offshore Procedure cases (and 0% penalty in Streamlined Foreign Offshore Procedure cases).
US tax compliance
Have counselled numerous clients facing criminal penalties and jail time, to come into US tax compliance with tolerable civil penalties.