Shannon Retzke Smith


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

She focuses her practice on sensitive tax matters, which often involve negotiations with government agencies. Shannon represents clients in a broad range of tax, trust, estate, and business planning issues. Her work involves planning for high net worth 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 a highly regarded tax controversy attorney who assists clients in resolving high-stakes, complex tax controversies. She regularly represents high net worth individuals, corporations, and partnerships facing federal or state tax liability. Shannon develops strategic responses and solutions 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 O'Bryan


“We were impressed by the excellent work and legal competence of Shannon Retzke Smith and her team. They were able to develop a compelling defense vis a vis the IRS resulting in fully eliminating a large penalty.” – German Kortschak

Track record





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

How to Survive an IRS Crypto Tax Audit,’ Forkast - November 24, 2021, co-author

‘Surviving an IRS Cryptocurrency or Other Crypto Asset Audit,’ Bitcoin Magazine - September 27, 2021, co-author

IRS removes one of four options to correct foreign reporting,’ Accounting Today - November 9, 2020, co-author

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

‘Updated Voluntary Disclosure Program,’ Surgent Accounting & Financial Education Expert Hour, May 27, 2021, speaker

‘Section 754 step-up in basis: Understanding the tax issues for partnerships and LLCs,’ Surgent McCoy, July 17, 2019, presenter

‘Foreign bank and financial accounts,’ Surgent McCoy, June 11, 2019, presenter



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