Successful DOJ Negotiation to Avoid Criminal FBAR Prosecution and Reduce Penalties by 69%
Successfully negotiated with the Department of Justice on behalf of a client who owned multiple offshore companies and bank accounts to DECLINE criminal prosecution for willfully failing to file Foreign Bank Account Reports ("FBAR") for 9 years, as well as reducing the civil willful FBAR penalties by 69% from the statutory maximums that applied in ...
What is the Texas Voluntary Disclosure Program?
Overview The Texas Voluntary Disclosure Program (VDP), administered by the Texas Comptroller of Public Accounts, allows businesses and individuals to report and pay previously unpaid or underpaid taxes voluntarily. This program incentivizes compliance by offering significant benefits, such as penalty waivers and, in most cases, interest waivers, fo...
What Services Are Subject to Texas Sales Tax?
Everything to Know About Service Sales Tax in Texas Navigating Texas sales tax on services is vital for businesses to stay compliant and avoid penalties. The Wilson Firm specializes in guiding clients through Texas tax regulations. Texas collects approximately $47 billion in sales tax annually, with services accounting for about 20% of taxable reve...
What is a Tax Treatise?
Learn Everything About Tax Treatise Navigating the world of tax law can feel overwhelming, with its intricate codes, regulations, and constant updates. Whether you're a business owner, an individual taxpayer, or a professional seeking clarity, having reliable resources is crucial. At The Wilson Firm, we understand the importance of accessible, auth...
Steps of a Texas Sales and Use Tax Audit
Everything to Know about Texas Sales and Use Tax Audits Facing a Texas sales and use tax audit can be daunting, but understanding the process can help your business prepare and navigate it with confidence. At The Wilson Firm, we specialize in guiding businesses through tax audits to ensure compliance and minimize risks. The Texas Comptroller of Pub...
What is the Federal Voluntary Disclosure Program?
Everything to Know About the VDP If you've ever worried about unreported income, offshore accounts, or other tax issues that might lead to serious consequences, the Voluntary Disclosure Program (VDP) could be a lifeline. As a federal tax program administered by the Internal Revenue Service (IRS), the VDP allows taxpayers to come forward voluntarily...
How To Apply For A Texas Sales Tax Permit
Everything to Know About Tax Permits in Texas If you're launching a new business in Texas or expanding your existing operations, understanding how to apply for a Texas sales tax permit is a critical step toward ensuring legal compliance and seamless business operations. A sales tax permit is not just a regulatory requirement; it’s a cornerstone of ...
The Wilson Firm Saved $1.1 Million in Worker Reclassification Audit Case
How We Successfully Defended Against IRS Worker Reclassification Claims The Wilson Firm's client was audited by the IRS regarding its payroll tax obligations from 2017 to 2021. The core issue was the classification of its workers: whether they should be considered employees or independent contractors. The Wilson Firm appealed the IRS's initial deci...
Strategic Victory: The Wilson Firm's Expert Negotiation Reduces ESRP Penalty from $465,000 to $9,000
How We Successfully Negotiated a Drastic Reduction in ESRP Penalties The Wilson Firm recently navigated a significant victory in Employer Shared Responsibility Payment (ESRP) penalty negotiation, dramatically reducing a client's ESRP penalty from $465,000 to just $9,000. In this case, The Wilson Firm adeptly demonstrated to the IRS that the company...
Another Win in a Streamlined Domestic Offshore Disclosure Case
How We Helped Reduce Offshore Tax Penalties by 87% Client worked for an international oil and gas company based in Europe, where the employees had the equivalent of a European 401k. The client was given erroneous advice and never reported this foreign account when filing their tax returns. Before coming to The Wilson Firm, the client was looking at...
The Wilson Firm’s Legal Victory for a Fortune 100 Corporation
How We Secured a $1.1 Million Property Tax Reduction for Our Client The Wilson Firm recently achieved a significant victory for its client, a subsidiary of a Fortune 100 company. The case involved a dispute with Montgomery Central Appraisal District over the value of approximately 30 acres of commercial property located in The Woodlands, Texas. The...
How to Settle Your IRS Tax Debt: Offer in Compromise (OIC) versus Installment Agreement
Choosing the Best IRS Payment Plan for Your Tax Debt Two of the most common payment options for delinquent tax debts are installment agreements and offers in compromise. Let’s discuss theses options below, along with the key considerations for choosing which route might be best in a taxpayer’s particular case. If you owe the IRS, and are considerin...
He Said, CSED: How Far The IRS is Willing to Go and What You Really Need to Know
Understanding the IRS Collection Statute Expiration Date (CSED) and Your Rights The Collection Statute Expiration Date, often referred to as the “CSED”, is the maximum time period the IRS will look back to collect unpaid taxes. Similar to a statute of limitation, where anything beyond that date is off-limits, the CSED is 10 years from the date the ...
Surprise! Spouse Leaves IRS Debt You Did Not Know About
How Innocent Spouse Relief Can Protect You from Tax Liability When filing a joint tax return, married taxpayers are often privy to certain tax benefits. Generally, married taxpayers take advantage of a higher standard deduction and a lower tax rate when filing their taxes together. However, as a result of a joint filing, both taxpayers are equally ...
Engaged and Worried About IRS Debt? What You Need to Know
Understanding IRS Debt and Community Property Laws in Texas Are you engaged to someone with significant IRS debt? Learn how community property laws in Texas might affect your earnings and property, and explore options to protect your financial interests. When Your Fiancé/Fiancée Owes Money to the IRS. Assume that A is engaged to marry B. They live ...
IRS Eases Penalty Assessment Rules for Late-Filed Foreign Gift and Inheritance Forms
Significant Relief for Taxpayers Reporting Foreign Gifts and Inheritances At the urging of the Taxpayer Advocate Service and practitioners, the IRS has ended its practice of automatically assessing penalties at the time of filing for late-filed Forms 3520 to report foreign gifts and inheritances. Also, by the end of the year, the IRS will begin rev...
Penalty Primer: Late or Unfiled International Information Returns
Written by Jack Naranjo Understanding IRS Penalties for Late or Unfiled Foreign Asset Reports At the urging of the Taxpayer Advocate Service and practitioners, the IRS has ended its practice of automatically assessing penalties at the time of filing for late-filed Forms 3520 to report foreign gifts and inheritances. Also, by the end of the year, th...
Streamlined Foreign Offshore Procedures
Overview The purpose of the Streamlined Foreign Offshore Procedures (“SFOP”) is to bring foreign or non-U.S. resident taxpayers into compliance for reporting foreign financial assets. In other words, SFOP provides taxpayers, who comply with the eligibility criteria outlined below, with amnesty from penalties such as failure-to-file and failure-to-p...
An Introduction to Form 5471 - Information Return of U.S. Persons With Respect to Certain Foreign Corporations
Purpose of Form Form 5471 is used to satisfy the reporting requirements of Internal Revenue Code (“IRC”) §§ 6038 (information reporting with respect to certain foreign corporations and partnerships) and 6046 (returns as to organization or reorganization of foreign corporations and as to acquisitions of their stock). Likewise, Form 5471 is used to r...
Fast Money Does Not Last
The Risks of Fraudulent Employee Retention Credit Claims A wise man once said, “Fool me once, shame on you; fool me twice, shame on me.” Whoever this so-called wise man was, he had never encountered the IRS. If he had, the corrected quote would be something like this: “Fool the IRS once, go straight to jail.” When it comes to trying to defraud the ...

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