Professional Services


Tax Crimes

Columbus Tax Crimes Defense Lawyers

Facing a tax crime, regardless of the charge, is a highly serious matter. Once the IRS is convinced of your guilt, they will aggressively pursue criminal investigation, prosecution, and a possible conviction.

If you have been accused of a tax crime, your choice of defense attorney can have a significant impact on the outcome of your matter. At this time, your interests will be best served by retaining a lawyer who has significant experience defending against IRS criminal charges.

Experienced Criminal Defense from a Former Prosecutor for the Department Of Justice

Attorney Terrence Grady is a highly sought-after tax lawyer and criminal defender. As a former prosecutor for the Department of Justice, he knows how the government will likely prepare its prosecution and how to assess weak spots in their case. With more than 30 years of legal experience, Mr. Grady has also developed a comprehensive knowledge of tax codes and IRS regulations. He easily understands complex criminal tax charges and as a result can create effective strategies for defending each individual client.

Attorney Grady and his team defend clients against a wide range of tax crimes, including:

  • Failure to file tax returns and underreported income
  • Signing and filing fraudulent tax returns
  • Tax evasion; failure to pay
  • Failure to pay payroll tax
  • Fraudulent business expenses
  • Fraudulent conveyance
  • International tax investigations

When you work with our Ohio law firm, we know your future and freedom are on the line. We focus on prompt resolutions through full dismissal, or favorable plea bargains when dropped charges are not realistic. While trial is not always a first choice due to the risk involved for our client, we are experienced litigators and are readily prepared to defend clients in the courtroom when necessary.

Learn more about criminal tax investigations through these frequently asked questions.

Get a Lawyer Involved Before the IRS Escalates Your Matter to the Criminal Division

While the majority of civil tax matters do not escalate to criminal charges, some do. As soon as you become aware of a civil tax investigation, contact our tax crimes defense attorneys.

Failure to File Tax Returns & Underreported Income

Failure to File Tax Returns

Failure to file tax returns or failure to accurately report your income can bring close scrutiny from the IRS and state taxing authorities. These government agencies have many resources at their disposal and investigations can quickly escalate into criminal charges.

Defending Against Criminal Charges for Failure to Report Income or Underreported Income

If the government alleges that you failed to file a tax return or filed a fraudulent return, it is critical to work with experienced legal counsel at the earliest opportunity. At Terrence A. Grady & Associates Co., L.P.A., we defend numerous individuals against a range of criminal tax charges, including failure to file.

Backed by more than 30 years of legal practice, and experience as a criminal tax prosecutor for the Department of Justice, Mr. Grady understands how the prosecution thinks. He also knows how to quickly assess individual circumstances and help his clients find the best possible solution for their specific matter.

There are many reasons why individuals fail to file tax returns or underreport their income. For some the return was too confusing to complete. Others did not have the money to pay back taxes. Many underreport income due to an honest error, misclassification or a mistake by their accountant. Regardless of your unique circumstances, there can be many viable defenses for unfilled tax returns. Our lawyers will help you explore all possible options and advise on the best route to resolution.

Trusted Results for Criminal Tax Matters

Because our lawyers only focus on tax law and federal white collar crimes, we are extremely well-positioned to address your charges of failing to file. Attorney Grady is known for his ability to resolve even the most difficult of criminal matters and is continually recognized by his peers and the legal profession for the results he obtains. He holds an A V Preeminent* rating from Martindale-Hubbell, has been named as one of the Best Lawyers in America and was selected for inclusion to the list of Super Lawyers from its inception in 2005 to 2014. Additionally, attorney Kate Dodson has also been recognized as a superior young lawyer and has been named to the Ohio Rising Star list for many years.

Contact Our Columbus Tax Lawyers

If you have been charged with failure to file tax returns, contact our Ohio law firm to discuss your matter with one of our experienced attorneys.

* A V Preeminent and BV Distinguished are certification marks of Reed Elsevier Properties Inc., used in accordance with the Martindale-Hubbell certification procedures, standards and policies. Martindale-Hubbell is the facilitator of a peer review rating process. Ratings reflect the confidential opinions of members of the Bar and the judiciary. Martindale-Hubbell ratings fall into two categories: legal ability and general ethical standards.

FAQ’s About Criminal Tax Investigations

Questions about Criminal Tax Investigations
What is the different between an IRS Special Agent, an IRS Revenue Agent, and an IRS Revenue Officer?
The IRS has two separate methods of conducting an investigation; civil audit examinations and criminal investigations. Additionally, the IRS has a separate division in charge of collecting unpaid tax liabilities. IRS Special Agents are the individuals charged with investigating criminal tax crimes. Accordingly, any contact made by an IRS Special Agent generally connotes a criminal investigation. Alternatively, the IRS also has civil audit examiners titled Revenue Agents. Revenue Agents are charged with conducting civil audit examinations. Lastly, the IRS Collection Division employs Revenue Officers to collect unpaid tax liabilities.
How do I know if the IRS has initiated a criminal investigation against me or my business?
An IRS Special Agent came to my house, what should I do?
I haven’t filed tax returns for many years, what should I do?

Fraud, Financial & Securities Crimes

Fraud, Financial and Securities Crimes Defense

After the recent financial crisis in our country, the government has taken a renewed interest in identifying and prosecuting those accused of fraud and securities crimes. The Securities and Exchange Commission and the FBI are working closely with federal attorneys in these matters, often building their cases for years before filing charges.

Federal financial crimes are highly complex and involve intricate financial regulations and reporting requirements. In order to present the best defense possible, those accused of financial crimes need to retain a highly criminal prosecutor with a strong financial background.

Experienced White Collar Crime Defense

At Terrence A. Grady & Associates Co., L.P.A., we provide high-caliber defense for a range of federal white collar crimes, including:
  • Securities crimes
  • Stock fraud
  • Investment fraud
  • Insider trading
  • Financial crimes
  • Structuring crimes
  • Mortgage fraud
  • Health care fraud
  • Money laundering
  • Wire fraud and bank fraud
Our client based is diverse and includes brokers, financial advisors, hedge fund managers, financial officers, doctors, property buyers, attorneys, CPAs, real estate professionals and a range of other individuals. Attorney Terence Grady leads our financial crimes defense practice. Mr. Grady has a strong financial background. With more than 30 years of legal experience in taxation, numerous and various businesses and business transactional work, and a wide array of white collar criminal defense matters, he also understands how to analyze complex financial documents, where to look for evidence to support your position and how to damage the credibility of the prosecution’s evidence against you.

Contact Our Columbus Attorneys for Fraud, Financial and Securities Crimes Defense

If you are being investigated or have been charged with a fraud or securities crime, do not talk to investigators. Your first step should be to call a lawyer. Contact our Ohio law firm for an initial review of your legal position and learn how we can help going forward.

Civil Tax Disputes & Litigation

Lady Justice — Litigation in Columbus, OH
IRS Tax Dispute

If you have received notice of an audit, investigation or collection from the IRS, do not ignore the matter. These problems will not disappear and the IRS will continue to pursue resolution by any means necessary. The best course of action is to consult with a qualified tax attorney. With proper legal representation, you may find solutions you did not realized existed and you will be made aware of IRS procedures and your rights and preparation of a proactive and responsive approach to your problem.

Effective Solutions to Civil Tax Disputes

Clients seek the legal services of Terrence A. Grady & Associates Co., L.P.A, because of our established reputation in tax law. Our civil tax controversy practice includes representation in all matters involving federal, state and local tax disputes with the IRS and the Ohio Department of Taxation.

Attorney Grady is consistently listed among the Best Lawyers in America for tax law, and brings over 30 years of legal experience to each matter, including time spent as a criminal tax prosecutor for the Department of Justice.

Our lawyers help clients resolve a wide range of civil tax disputes, including:
  • Individual income tax audits and appeals
  • Audits of estate and gift tax returns
  • Corporate income tax audits and appeals
  • Payroll tax disputes/trust fund recovery penalty
  • IRS collections, liens and levies
One of the many benefits to working with our firm is the hands-on attention you will receive from your attorney. We do not pass your important tax matter off to less experienced associates. We understand the importance of quickly resolving your tax disputes, so your lawyer will provide the customized solutions that you need.

Prevent Your Civil Matter from Turning into a Criminal Matter

If you are faced with a civil tax dispute, it is important to retain an experienced tax attorney as soon as possible. There is always risk that the IRS will refer a matter to the criminal investigation division. With the help of a tax lawyer, you can protect yourself from criminal charges and find swift resolution to your civil matter.

Contact Our Ohio Civil Tax Litigation Attorneys

If you have been assessed with additional taxes, face an audit or appeal, or have received notice of any other tax investigation or collection effort, our law firm can help. Contact our IRS tax dispute lawyers in Columbus to learn more.

Businesses and Individual Income Tax Audits & Appeals and Tax Litigation

IRS Tax Audit

At Terrence A. Grady & Associates Co., L.P.A., we provide skilled legal representation to clients who face IRS tax audits and appeals. While many individuals do not need the help of a tax attorney during these IRS disputes, if you have been unfairly assessed or face complex audit issues, our lawyers can help.

Protecting Your Interests during IRS Audits and Appeals

Our law firm is backed by decades of tax experience. All of our attorneys have advanced degrees in taxation and the majority of our work is focused on resolving tax issues. We have a solid understanding of all tax codes and IRS regulations and procedures, and we are able to easily identify legal facts to support your position.

Facing an audit means dealing with IRS agents specifically trained to find errors and omissions in your returns. They will dig deep into your past returns, financial accounts and business records. When the IRS agents make accusations based on their findings, it can leave you vulnerable for substantial assessments. While the IRS may see red flags with items such as passive activity loss, income not being reported or excessive business expenses, our lawyers know how to defend your position with valid legal arguments.

It is important to remember that an initial assessment or audit determination from the IRS does not have to be the final one. We can appeal your matter. Our lawyers understand how to negotiate with the IRS. With skilled legal research and evidence, we can help eliminate additional assessments, penalties and fines; or find alternative repayment solutions that are manageable for you.

Contact Our Ohio Lawyers for Help in Appealing Tax Audits

If you are a small-business owner, an individual in a high tax bracket, or face any other complex tax issues, contact our Columbus law firm for help with your IRS audit or appeal. The government uses significant resources to collect on money it feels it is owned. Do not attempt to resolve these matters without the legal strength of a qualified tax attorney.

Payroll Tax Disputes/Trust Fund Recovery Penalty

Payroll Tax Disputes

Every employer has a legal obligation to withhold Social Security tax, income tax and Medicare tax from employee paychecks. The employer is required to hold this money in trust for the government and submit annual tax payments. If an employer does not make these deposits to the government, they may face civil penalties and fines, and in the most serious cases, even criminal charges. In fact, in appropriate situations, the IRS has the ability to criminalize the failure of a business to pay over payroll tax liabilities. Accordingly, a business and its owners who have fallen into financial distress and have failed to pay over payroll tax liabilities to the IRS must be extremely sensitive to the possible criminalization of this behavior. Additionally, the IRS can aggressively try to collect these delinquent liabilities.

Worker Misclassification

In some instances, the IRS and State agencies challenge how a business classifies its workers as either independent contractors or employees of the business. In appropriate circumstances, workers do qualify as independent contractors versus employees for federal and state tax purposes. Unfortunately, a misclassification, even an innocent one, can have very severe ramifications and can be very costly to a business. Our attorneys have significant experience in the analysis and established tests developed under the tax laws and can initially consult on and provide advice on the proper classification and/or can defend against a reclassification by the IRS or State taxing agencies.

The Trust Fund Recovery Penalty

The IRS does not tolerate nonpayment of payroll taxes and will use aggressive collection efforts to secure these outstanding tax liabilities. In accordance with the Trust Fund Recovery Penalty, the IRS can seize company assets to satisfy past due payroll taxes. In addition, owners of small businesses and those in a position to collect/pay payroll taxes can also be held personally liable for the business’ delinquent payroll liabilities. In these cases, the IRS can place liens or levies on personal property and accounts.

Finding Solutions to Payroll Tax Disputes

For those facing audits or collection regarding payroll taxes, dealing with the IRS can be confusing and intimidating. However, it is important to remember that you have legal rights and there may be many available options for favorably resolving your matter. The key is to work with an experienced tax lawyer.

At Terrence A Grady & Associates Co., L.P.A, our lawyers excel in negotiating with the IRS for fair repayment terms and also have significant experience appealing IRS determinations in Trust Fund Recovery Penalty cases. All of our lawyers have advanced degrees in taxation and are able to quickly identify best options for resolution based on the specific circumstances of each client. Whether an accounting mistake was made, or if you simply got behind in payroll taxes and could not catch up, we will help find a solution you can live with.

Contact Our Ohio Attorneys

Contact our Columbus law firm to discuss your options for resolving a civil payroll tax dispute.

IRS Collections, Liens & Levies

Tax Form — IRS Collection in Columbus, OH
IRS Collections, Liens and Levies

The IRS can be unforgiving when it comes to unpaid taxes. When an individual does not submit taxes as owed, the government will employ dedicated collection agents to secure past due tax payments through any means necessary. When financial repayment is not obtained, the IRS is quick to proceed with alternative collection methods, including liens and levies, and garnishments.

Understanding IRS Liens and Levies

Liens and levies are an aggressive IRS collection tool used when the taxpayer has made no attempts to satisfy his or her outstanding tax liabilities. In the most extreme cases, the IRS can take your property through levy actions or lien foreclosures. However, wage and bank levies and garnishments are the more common collection methods in these circumstances.

The IRS will typically send multiple notices of tax liability before commencing a lien or levy action. If no communication is initiated on your part or no repayment solution has been reached, the government will begin a lien or levy. This can be devastating and stressful for you and your family. However, it is important to realize there are legal solutions. With the help of a skilled tax attorney you can stop these drastic collection efforts and find alternative methods of repayment.

Helping You Stop the Drastic Collection Efforts of The IRS

At Terrence A. Grady & Associates Co., L.P.A., our lawyers have helped a significant number of individuals and families stop IRS liens and levies through effective legal strategies. We have a dedicated focus on tax law and have an in-depth understanding of the multiple resolution options for those who face extreme collection methods.

The best time to contact our law firm is upon the first notice you receive. If we are involved early, we can work to prevent a lien or levy. However, if these actions are already in process, it is not too late for a favorable resolution. We are skilled in halting liens and levies, and negotiating with the IRS for alternative repayment plans.

Contact Our Columbus Tax Law Attorneys

There are many options to help you resolve IRS collections, liens and levies. Contact our Ohio law firm to learn more.

Options to Settle Tax Liabilities

Options to Settle Tax Liabilities

Living with substantial tax debt is stressful and overwhelming, yet many individuals take no action because they do not see any viable solutions. However, if you have tax liabilities, doing nothing is the worst course of action. If the IRS or state taxing authorities do not yet know about your delinquencies, they eventually will. And if you do not attempt to resolve your tax debt now, you could face both civil and criminal penalties later. The best possible action is to consult with an experienced tax lawyer.

Serious Tax Issues Require Serious Legal Representation

If you have significant tax liabilities, Terrence A. Grady & Associates Co., L.P.A., can help you explore many options for resolving your debt, including:

  • Offers in compromise
  • Installment agreements
  • Partial payment installment agreement
  • Innocent spouse relief
  • Penalty abatements
  • Currently not collectable
  • Bankruptcy Options (yes, income tax liabilities can be discharged in bankruptcy)

There are numerous factors which will determine eligibility for each option, including the nature of your outstanding tax liabilities and your current financial situation. While anyone with tax debt can benefit from qualified legal advice, those with more than $75,000 of unpaid taxes should seriously consider retaining a tax attorney.

Our Approach to Resolving Your Matter

Our lawyers work quickly to develop a relationship of trust with our clients. By fully understanding our clients’ financial condition and hardships, we are able to develop realistic and personalized repayment plans. Unlike many of the mass-marketing firms, we do not waste our clients’ time or resources by suggesting unavailable or unworkable plans. Our combined backgrounds in taxation and litigation and our vast collection representation provide our clients with the professional and competent counsel they need to effectively and efficiently deal with their tax liabilities.

Unpaid Taxes and the Statute Of Limitations

After 10 years from the date of your tax liability assessment, the IRS cannot take any additional collection actions without filing a lawsuit in federal district court. However, there are some actions, such as a bankruptcy, collection due process appeal, or an Offer in Compromise filing, that may extend the amount of time the IRS can collect against an outstanding tax liability. Accordingly, taxpayers with substantial tax debt must be fully aware of the options available for relief of these liabilities but also aware of other ramifications relating to a specific remedy.

A Note about the Fresh Start Initiative

The IRS made recent changes through the implementation of its “Fresh Start Initiative” that makes it easier for delinquent taxpayers to qualify for installment agreements and allows for more flexible terms in the Offer in Compromise program. While these changes have brought much needed relief to thousands of individuals, it is still important to consult with a tax lawyer regarding the best options for your specific circumstances.

Contact Our Ohio Lawyers

Learn how our attorneys can help you explore options to settle tax liabilities. Contact our Columbus law firm to schedule an initial consultation.

Offers in Compromise

What Is an Offer in Compromise?

The IRS’ Offer in Compromise program is the only mechanism by which the IRS will agree to take less than what the taxpayer owes to resolve outstanding tax liabilities.

Do I Qualify for an Offer in Compromise?

What payment options are available for the Offer in Compromise program?

How long will it take for the IRS to review my Offer in Compromise?

Why “Pennies on the Dollar” Is Not Realistic

Contact Our Ohio Tax Settlement Lawyers


Installment Agreements

Installment Agreements

For those with significant tax liabilities, a lump-sum payment to settle their tax debts may not be a realistic option. Unfortunately, if nothing is done to resolve this outstanding debt, the IRS will waste no time pursuing wage/bank garnishments or property liens/seizures. However, there are many options for settling tax liabilities and an installment agreement can give you the financial breathing room that you need.

Understanding Installment Agreements

When the IRS accepts installment agreements, it allows delinquent taxpayers to settle tax debt through monthly payments made over a period of time. For those who are facing immediate IRS levies or property seizure, this solution brings much needed relief. Once an installment agreement is entered into, the law requires that all IRS collection efforts cease. While the IRS may still place a lien on your property, they cannot act upon it if you make regular payments as agreed upon.

It is important to note that penalties and interest will continue to accrue each month on any outstanding portion of the tax debt.

Do Not Try To Negotiate With the IRS on Your Own

When proposing the terms of an installment agreement, the IRS will typically take into account your liquid assets as well as your family’s business’s allowable expenses. However, the IRS is not always fair or realistic when creating these agreements. That is one of the main reasons it is important to seek legal advice from a qualified tax attorney.

At Terrence A. Grady & Associates Co., L.P.A., tax law is our main focus. When the IRS presents an unrealistic installment agreement, our lawyers can help. We are very familiar with the IRS’s internal policies and procedures related to these collection alternatives and know what arguments to make to get you the most reasonable monthly payment arrangement. We also have the legal knowledge and skill to negotiate a better offer that is viable for our clients and also satisfactory to the IRS.

With more than 30 years of legal experience, attorney Grady is consistently listed among the Best Lawyers in America for taxation issues. He understands the complex IRS regulations associated with installment agreements and has helped a significant number of clients find solutions to outstanding tax debt.

Our law firm can facilitate installment agreements for individuals, families and businesses.

Contact Our IRS Payment Plans Lawyers

Learn how our Ohio law firm can help you satisfy payment of your back taxes through an installment agreement with the IRS. Contact our Columbus tax attorneys to learn more.

Penalty Abatement

IRS Penalty Abatement

Penalty abatement can allow individuals and businesses to reduce or eliminate the penalties, fines and interest associated with failure to file tax returns and past due tax payments. Generally speaking, penalty abatement is not the first course of action when seeking to settle tax liabilities. It may, however, be a realistic option during an appeal of your civil tax dispute. Regardless of the circumstances, the IRS does not grant penalty abatement freely or regularly. Rather, the taxpayer must show that he/she/it meets the established standards for abatement or the imposition of penalties in any particular case. Those who can show reasonable cause for why they did not file or pay taxes within the required time frame will have the greatest chance of obtaining penalty abatement. Conversely, if the IRS determines that an individual or business showed willful neglect in failing to file or failing to pay, they will not grant a penalty abatement. Our attorneys are very conversant with these standards and can provide a realistic assessment of the taxpayer’s chances of success in pursuing a penalty abatement. This is important as the Taxpayer does not have resources to waste by pursuing relief or taking positions that are likely not going to be successful.

Resolving the Fines Associated With Failure To Pay Taxes Or Failure To File

While obtaining a penalty abatement is challenging, it is not impossible. When you work with Terrence A. Grady & Associates Co., L.P.A., we will conduct a full analysis of your position and help you understand the best options for settling your tax liabilities. If a penalty abatement is realistic, we are confident in our ability to help you obtain it.

It is important to note that even if you are granted an abatement of penalties, you will likely still be responsible for the full amount of taxes owed. Each individual and business will face a different set of circumstances, so it is important to get personalized legal counsel before proceeding with your matter. As a boutique tax law firm, our attorneys can offer high-level tax knowledge not often seen at general practice firms. And as a smaller firm, we are able to provide each client with individual strategies and legal plans.

Contact Our Columbus, Ohio, Lawyers

Learn how our IRS penalty abatement attorneys can help you. Contact our law firm to schedule an initial consultation.

Foreign Bank Account & Foreign Entity and Investment Reporting

Foreign Bank Account and Foreign Entity Reporting

In an effort to bring transparency to foreign bank accounts and entities, the IRS has strict compliance regulations and reporting requirements. Failing to meet the imposed guidelines can bring about harsh civil penalties, and may even result in criminal prosecution.

International Tax Lawyers

At Terrence A. Grady & Associates Co., L.P.A., protecting our clients’ best interests and their foreign investments is our main priority. Our legal team has a dedicated focus on international taxation and is led by highly respected tax attorney Terrence Grady. Mr. Grady brings more than 30 years of experience in complex legal taxation issues and has been listed among the Best Tax Lawyers in America for multiple years.

If you have assets or business interests abroad, our law firm can help you with:

  • Proper formation of business entities
  • Legal compliance issues associated with owning foreign real estate
  • Reporting requirements for foreign bank accounts and investments
  • Preparing annual Reports of Foreign Bank and Financial Accounts (FBAR)
  • Assist with filings under the Voluntary Disclosure Initiative

Reporting Requirements for International Bank Accounts and Investments

If you are a U.S. citizen with more than $10,000 in an offshore financial account, you are required by law to file an annual Foreign Bank Account Report (FBAR). If you do not, you could face substantial fines and even criminal charges. In addition to the annual FBAR (FinCen Report 114), there is a new disclosure required through the implementation of the Foreign Account Tax Compliance Act (FATCA). The IRS Form 8938 is required to be included with your annual income tax return if you have specified foreign assets that meet the specific filing thresholds.

Our lawyers can help you understand these reporting requirements and make the necessary annual filings on your behalf. For those who have not been compliant with foreign asset reporting in the past, the IRS’s Offshore Voluntary Disclosure Initiative and the various other disclosure options offer a way to disclose all foreign investments to the government, without risk of criminal prosecution.

Legal Compliance for Foreign Business Entities

Owning a business abroad or having a portion of your business operations in another country can bring many financial rewards. However, the U.S. government imposes strict formation and tax guidelines on such entities. These regulations can even extend to those who simply own international real estate or property.

Further, through the 2010 enactment of the Foreign Account Tax Compliance Act (FATCA), the rules and regulations on U.S. businesses with global operations are even more complex.

Our law firm can advise you on the many regulatory aspects of international business operations, beginning with entity selection and proper formation, FATCA impact assessments and compliance plan formation to ongoing advisement in IRS reporting. Our goal is to keep you legally compliant, protect your company from IRS investigations and position your business for continued success.

Contact Our Ohio FBAR Tax Lawyer

Contact our Columbus law firm to learn how we can help with your U.S. tax compliance, foreign bank account and foreign entity reporting, and FATCA compliance.

IRS Voluntary Disclosure Initiative

Resolving Delinquencies in Foreign Investment Reporting

For those with delinquencies in foreign bank account or foreign entity reporting, the Offshore Voluntary Disclosure Program provides a solution. Through this initiative, you have the ability to become current on foreign investment reporting and past due tax payments without the risk of criminal prosecution. As part of the program requirements, the government mandates that you pay all back taxes and interest, provide the previous eight years of income tax returns and pay a miscellaneous penalty fine.

While this program offers relief to a number of individuals, it is important to note that international reporting requirements are complex. Additionally, the IRS recently opened additional disclosure options (including the streamlined filing compliance procedure). These additional disclosure options are much more lenient and less punitive to taxpayers who negligently failed to make proper disclosures. Given all the complexities in the area, it is highly advisable to seek counsel from an experienced tax attorney before proceeding.

An Established International Tax Attorney

At Terrence A. Grady & Associates Co., L.P.A., our lawyers place a strong emphasis on international tax law, foreign investment reporting and IRS compliance. Backed by more than 30 years of legal experience in domestic and international taxation issues, attorney Grady has a full understanding of IRS regulations, tax codes and international reporting requirements. For those who are delinquent in foreign investment reporting, we provide skilled legal guidance throughout the Voluntary Disclosure process to ensure legal compliance.

After helping you become current on past due taxes and international reporting requirements, our law firm can also provide an annual review of your foreign accounts and investments to help you avoid IRS issues in the future.

Contact Our Ohio Lawyers about the Offshore Voluntary Disclosure Program

Our attorneys can help you make use of this beneficial initiative. Contact our Columbus law firm to learn more about your options.

International Tax Audits and Investigations

International Tax Audits and Investigations

In recent years, there has been an increase in IRS investigations of those who own international property, have assets in foreign accounts or have business operations abroad. There does not need to be a specific red flag in your tax reporting to initiate these types of investigations – simply having foreign real estate, financial accounts or business interests can be enough to trigger a supplemental review.

Protecting Your Interests During an International Tax Investigation

The IRS typically begins an international compliance review by sending a notice of investigation. This does not necessarily signal a full blown audit; however, due to the complexities associated with international tax reporting, it is important for you to get an attorney involved right away.

At Terrence A. Grady & Associates Co., L.P.A., our lawyers have established themselves as leaders in the area of international tax law and compliance. All of our attorneys have advanced degrees in taxation and meaningful experience in foreign investment regulations. Due to our dedicated focus in this practice area, we are well-positioned to address international tax audits and investigations efficiently and effectively.

While the majority of foreign tax audits are civil cases, it is possible for the matter to escalate to criminal investigation if the IRS suspects an individual of a tax crime. When you work with our law firm, we will begin protecting your interests from day one. Our lawyers quickly assess your legal position and identify practical solutions that will safeguard your best interests as well as satisfy the IRS.

Contact Our Ohio International Tax Lawyers

Upon notification of an IRS investigation into your foreign investments, contact our Columbus law firm at once. Do not discuss the matter with any IRS agents. You risk giving the government information to use against you.

Foreign Account Tax Compliance Act (FATCA) Assessment & Compliance Planning

FATCA Impact Assessments & Compliance Planning

The United States, in response to the Swiss bank account scandal and to increase global tax transparency, enacted the Foreign Account Tax Compliance Act (“FATCA”). FATCA has three major regulatory components including (1) individual filing requirements (a new IRS disclosure form 8938 for specified foreign assets); (2) foreign entity registration and U.S. withholding requirements; and (3) intergovernmental agreements with foreign governments. The new individual reporting requirements under FATCA create new disclosure requirements for individuals with foreign bank accounts and other foreign investments. It is important for you to understand these new reporting requirements and ensure that your tax professional is aware of all of your foreign investments to ensure proper and timely disclosures. Contact the attorneys at Terrence A. Grady & Associates Co., LPA to determine whether you are in current compliance and what options are available to you to correct any previous filing delinquencies related to the new FATCA disclosure form.

In addition to the onerous individual reporting requirements under FATCA, there is also a whole regulatory component for foreign entity registration and withholding requirements for U.S. withholding agents. These foreign entity registration requirements require specific foreign entities to register with the IRS and enter into an agreement to report information regarding their U.S. accounts. The new tax law is very complex regarding who is required to register and the consequences for failing to comply under FATCA.

In addition to the very significant regulatory scheme for foreign entity registration, FATCA imposes very significant tax withholding and reporting obligations on U.S. withholding agents who are making payments to foreign entities. Any U.S. businesses with foreign operations will need to understand the impact FATCA has on its operations and ensure that it is properly documenting all offshore payments. Failure to comply with these reporting and disclosure requirements under FATCA could result in significant penalties being assessed against U.s. businesses.

The attorneys at Terrence A. Grady & Associates can provide your global business with a FATCA impact analysis that addresses all of the new regulatory requirements under FATCA and alerts you to the changes that need to be made to internal policies and procedures in order to ensure 100% tax compliance. Additionally, we can work with your business to tailor a compliance plan to ensure that all record retention requirements under FATCA are implemented in your business structure and that your accounts payable function understands the withholding obligations for offshore payments.

Contact our FATCA Tax Attorneys

The Foreign Account Tax Compliance Act imposes a variety of new disclosure, reporting, and registration requirements on U.S. and foreign individuals and businesses. Failure to comply with these new regulatory requirements could result in very serious penalties and fines against you and/or your business. Contact our FATCA tax loss specialists to assist you in understanding the new tax law and your requirements and the impact it has on you and your business.