IRS Controversy -- International Tax

International tax matters are among the IRS's highest enforcement priorities. The agency has invested heavily in training examiners, developing data-sharing agreements with foreign governments, and building specialized teams focused on cross-border compliance. When an international tax dispute arises -- whether through an audit, a penalty assessment, or a question about a specific filing -- having experienced representation is not merely advisable; it is essential. At Lanphier LLP in Denver, we bring deep technical knowledge and practical experience to every international tax controversy engagement.

International tax controversies differ from domestic disputes in several important ways. The penalties are often larger, the factual questions are more complex, and the applicable law frequently involves the intersection of the Internal Revenue Code, Treasury regulations, tax treaties, and foreign law. The IRS agents assigned to international cases are typically among the most experienced and technically proficient in the agency. Effective representation requires a team that can meet these agents on equal footing -- and that is exactly what we provide.

International Tax Controversy Services

Audit Defense

We represent taxpayers in Denver and throughout Colorado before the IRS in examinations involving international issues, including transfer pricing, foreign tax credit claims, treaty-based positions, Subpart F and GILTI inclusions, FIRPTA transactions, and information return compliance. Our approach combines thorough factual preparation with strong technical advocacy to achieve the best possible outcome at the examination level.

Penalty Abatement and Reasonable Cause Defense

Many international tax penalties -- including those for late or incomplete Forms 5471, 3520, 8865, and others -- are assessed automatically and can reach staggering amounts. However, these penalties can often be abated if the taxpayer can demonstrate reasonable cause for the failure. We prepare detailed reasonable cause statements and supporting documentation, drawing on our experience with what the IRS finds persuasive in these cases. We have successfully reduced or eliminated penalties for numerous clients facing international filing deficiencies.

Voluntary Disclosure and Streamlined Procedures

Taxpayers who have failed to report foreign income or file required international information returns may be eligible for the IRS's Streamlined Filing Compliance Procedures or, in more serious cases, may need to make a voluntary disclosure. These programs offer a path to compliance with reduced penalties, but they must be navigated carefully. We guide our clients through the process, prepare all required filings, and advocate on their behalf to achieve the most favorable resolution available.

Appeals and Litigation Support

When an examination cannot be resolved favorably, we represent taxpayers in administrative appeals before the IRS Office of Appeals. Through our partnership with Dennis M. Lanphier, P.C., we can also provide representation in Tax Court and other judicial proceedings when litigation becomes necessary. This seamless integration of accounting and legal expertise is a significant advantage in complex international disputes.

If you are facing an IRS examination, penalty assessment, or other dispute involving international tax issues, contact our Denver office immediately. Early engagement gives us the best opportunity to protect your interests and resolve the matter efficiently.