Tax Controversy & Offshore Audits
Ketcham PLLC represents taxpayers in audits and other disputes with the IRS and state/local tax authorities. These matters range from examinations related to syndicated conservation easements (both SCE investors and alleged promoters), sales/use tax audits, payroll tax compliance, Schedule C audits, residency audits, and other domestic tax issues to information return compliance, offshore bank accounts, foreign-based entities and investments, and other international tax issues. Mr. Ketcham has particularly extensive experience handling offshore audits involving FBAR, Form 3520, Form 5471, Form 8938, and other potentially significant penalties related to foreign assets. With deep knowledge of U.S. tax law and IRS procedures, Mr. Ketcham is a battle-tested tax advocate and is often able to convince tax examiners to resolve audits on terms highly favorable to the client. And, if an audit cannot be favorably resolved at the examination stage, Mr. Ketcham also has extensive experience negotiating settlements with the IRS Office of Appeals and litigating tax issues in the U.S. Tax Court or the U.S. District Courts.