Shannon Retzke Smith

Partner | New Haven

Shannon is a partner in the private client and tax team.

She represents clients in sensitive tax matters, many of which involve negotiations with government agencies. Shannon provides clients with advice on a broad range of tax, trust, estate, and business planning issues. Her work involves planning for wealthy US and international families, with particular emphasis on planning for closely held businesses. Shannon’s planning work for clients involves a range of matters, from creating tax-efficient wealth transfer structures to addressing income tax issues arising from investments and operating businesses. She has advised prominent politicians, business people and well known athletes. She is known globally as one of the go-to attorneys for individuals with US tax or reporting issues and has represented clients from over 20 countries in the last year.

She is an experienced tax controversy attorney who assists clients in resolving high-stakes, complex tax controversies. Her clients include individuals, corporations, and partnerships facing federal or state tax liability. With her extensive income tax planning background coupled with her understanding of the tax controversy process, Shannon develops strategic responses and solutions with a goal to resolve a client’s matter privately at the earliest possible point while securing the best possible result.

In addition to the traditional tax controversies, such as representing clients in an audit, she has extensive experience in advising clients on issues regarding foreign bank account reporting (FBAR) obligations, the Foreign Account Tax Compliance Act (FATCA), and the Internal Revenue Service’s 2009 Offshore Voluntary Disclosure Program, 2011 Offshore Voluntary Disclosure Initiative, 2012 Offshore Voluntary Disclosure Program, 2014 Offshore Voluntary Disclosure Program, Streamlined Filing Procedure and other means of resolving US income and reporting deficiencies. Shannon has represented hundreds of U.S. taxpayers with undisclosed foreign bank accounts.

Secretary Elizabeth OBryan

Track record

Admissions

Publications

Memberships

Talks

Represented numerous individuals with undeclared bank accounts in offshore jurisdictions seeking amnesty under an IRS Voluntary Disclosure Program such as the Offshore Voluntary Disclosure Initiative (OVDI), Offshore Voluntary Disclosure Program (OVDP), Streamlined Domestic Filing Procedure, Streamlined Foreign Offshore Procedure, Delinquent FBAR Submission Procedure and Delinquent International Information Return Submission Procedure.

Negotiated with IRS for a decrease in the civil miscellaneous penalty associated with the Offshore Voluntary Disclosure Program based on partial compliance, alternative statutory framework, etc.

Represented TEFRA Partnership in IRS examination that was settled at the exam level obtaining seven figure penalty relief from the proposed adjustment.

State of Connecticut, 2004

State of New York, 2005

US Tax Court, 2011

‘Clean up your foreign reporting deficiencies before its too late,’ Forbes - June 3, 2018, quoted

’5 points to consider as overseas disclosure program ends,’ Law360 - May 14, 2018, quoted

‘Tax tips for US expats living in Australia,’ Business Insider Australia - May 8, 2018, quoted

Connecticut Department of Revenue Services

Zoe’s Best Friend Foundation

Cornell University Alumni Admission Ambassador Network

Connecticut Bar Association

American Bar Association

New York Bar Association

‘Foreign Bank and Financial Accounts,’ Surgent McCoy - June 11, 2018, presenter

‘Understanding the Foreign Account Tax Compliance Act,’ Surgent McCoy - June 8, 2018, presenter

‘Willfulness and the IRS Disclosure Programs: Are You Compliant?’, The Knowledge Group - October 11, 2017, presenter

Education


Languages


  • English

Dates


Joined

2004
Partner

2013

Recognition


New Haven

157 Church Street,

CT 06510-2100

View Office

Regularly works with...