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Los Angeles Tax Attorney

Los Angeles is home to businesses in many different industries, making it one of the busiest economic epicenters in the world. Every company has tax implications it must meet in order to remain in compliance with regulations. To meet those requirements, it is in the best interest of your company to find an experienced and reputable Los Angeles tax lawyer that would be able to advise you along the way. The experienced team of tax law attorneys at Abajian Law is comprised of high-powered and proven professionals including:

  • Vic Abajian, a former IRS Office of Chief Counsel senior tax attorney with trial experience
  • Aksel Bagheri, a proven tax lawyer with over a decade of experience
  • Berj Dersahakian, a leading tax attorney with a Corporate Finance Professional Certificate from Columbia University

Our entire team is ready and able to tackle any tax issues facing you or your company.

About Abajian Law

As a wealthy individual, corporation, or small business owner, when you’re facing an audit, income tax examination, tax penalties, or difficulty meeting tax requirements, a strong tax attorney can make the world of a difference. Vic Abajian previously worked at the IRS as a senior tax trial attorney. He brings with him those years of experience to private practice in an effort to help businesses in every industry, and of any size, deal with the tax laws of California and the United States.

Vic Abajian – Former IRS Lawyer

During his time as an IRS lawyer, Vic Abajian accomplished the following with the IRS:

  • Represented the IRS Commissioner before the United States Tax Court in all
    phases of litigation and trial;
  • Advised IRS Exam, Appeals, and Collection groups on substantive and
    procedural issues relevant to the assessment and collection of tax for individuals,
    limited liability companies, partnerships and corporations; and
  • Worked as a team leader in the Abusive Tax Avoidance Transaction program and helped develop I.R.C. § 6700 promoter cases for prosecution by the Department of Justice.

Prior to joining the IRS, Mr. Abajian worked for a boutique tax law firm in Los Angeles, representing companies in front of the IRS, FTB, and EDD. He provided the following services for clients:

  • Reviewed the tax planning strategies and made improvements;
  • Helped form corporations and LLC partnerships;
  • Provided estate planning services; and
  • Advised companies on other tax issues

After working for the IRS and before founding Abajian Law in 2006, Mr. Abajian worked for Deloitte, LLP, in Los Angeles as a member of the firm’s tax controversy group. His responsibilities as a member of the tax controversy group at Deloitte, LLP, included the following:

  • Responded to Notices of Proposed Adjustments, Information Document Requests
    and other inquiries by the IRS
  • Resolved complex tax controversies for corporations and individuals
  • Conducted research on complex tax issues
  • Advised the many tax groups at Deloitte, LLP, on complex tax issues
  • Worked on a broad group of tax issues for clients of the firm

Areas of Tax Law

Mr. Abajian and the Abajian Law team have experience handling issues in various areas of tax law, including the following:

Tax Controversy

Tax controversy is a legal practice area that involves handling disputes between individuals and companies with various entities, including the IRS, as a result of an audit. We understand that each tax controversy issue is different, urgent, and stressful. The Abajian Law team will build a case that is tailored to each individual client based on their situation and needs when dealing with the IRS.

Our Los Angeles tax lawyer provides the following tax controversy services to our clients – individuals as well major businesses and corporations:

  • Examinations
  • Pre-controversy audit preparedness
  • Proactive solutions to resolutions
  • Litigation, appeals, and settlements
  • Establish transfer pricing policies, practices, and documentation

Tax Litigation

Mr. Abajian and the Abajian tax law team have years of experience representing clients at trial over tax issues. We do not shy away from going to trial in an effort to resolve tax controversies and other tax-related issues for individuals and companies in California. Our tax team represents clients in the following litigation matters:

  • District court litigation
  • Tax Court
  • Filing administrative appeals
  • Audits

Our litigation services include:

  • Estate and gift taxes
  • Tax credit qualifications
  • Excise taxes
  • Financial products
  • Exempt organization qualifications
  • Worker classification issues
  • Transfer pricing
  • Partnership issues
  • Employment taxes
  • Withholding tax issues
  • Tax treaty issues
  • State and local tax issues
  • Controversies involving the Tax Cuts and Jobs Act
  • Financial products

Offshore Bank Accounts & FBAR

The Los Angeles tax lawyer at Abajian Law has experience handling issues related to offshore bank accounts and the Reporting of Foreign Bank and Financial Accounts (FBAR). The requirement to declare foreign bank accounts was established in 1970 by Congress as part of the Currency and Foreign Transactions Reporting Act of 1970. This then became known as the Bank Secrecy Act (BSA).

Under the law, United States Persons including citizens, residents, corporations, limited liability companies, partnerships, and trusts and estates must file an FBAR report:

  • a financial responsibility or authority over one financial account that is held outside of the United States if the aggregate value of the account exceeded $10,000 in value at any time during the calendar year for which you are filing taxes

Failing to file an FBAR report can result in criminal penalties, such as an indictment. Civil penalties include as much as half of the balance of the account if the IRS deems that the failure to report was reckless or willful in nature. The penalties from the IRS are as follows:

  • 31 U.S.C. 5321(a)(5)(B)(i) Foreign Financial Agency Transaction – Non-Willful
    Violation of Transaction – $12,921
  • 31 U.S.C. 5321(a)(5)(C) Foreign Financial Agency Transaction – Willful
    Violation of Transaction –Greater of $129,210, or 50% of the amount per 31
    U.S.C.5321(a)(5)(D)
  • 31 U.S.C. 5321(a)(6)(A) Negligent Violation by Financial Institution or
    Non-Financial Trade or Business – $1,118
  • 31 U.S.C. 5321(a)(6)(B) Pattern of Negligent Activity by Financial Institution or
    Non-Financial Trade or Business – $86,976

Tax Fraud & Crimes

Federal income tax fraud falls into two categories: criminal and civil. Under criminal tax fraud, the government can enforce jail time and probation for violators of the tax law. Civil tax fraud penalties include the loss of assets and money.

The most common crimes under criminal tax fraud include the following:

  • Evasion of assessment
  • Tax evasion
  • Willful failure to pay or collect over tax
  • Evasion of payment
  • Failure to pay tax, file a return, or supply information to the IRS

There is no general statute of limitations when it comes to assessing penalties for civil tax fraud. However, the government has six years to bring criminal charges against an individual or entity for criminal tax fraud.

When it comes to the burden of proof in a civil tax fraud case, the government is required to show clear and convincing evidence that tax fraud occurred. In a criminal tax fraud case, the government is required by the Constitution to prove that every element of the statute involved in the case has been proved beyond a reasonable doubt.

International Tax Law

Tax law is complex, and international tax law is one of the most complex tax arenas. Abajian Law can represent expatriates and businesses in dealing with international tax law problems. As a business, our Los Angeles tax lawyer can assist with the following international tax law considerations:

  • Liability
  • Tax treatment of your business
  • Capital considerations
  • Formation and administration of the business
  • Creation of an exit strategy

The tax requirements of a foreign corporation depend on the entity’s status as a foreign corporation doing business in the United States or as a domestic United States corporation. If you are a foreign-owned domestic corporation, you are required to file Form 5472, Information Return of a 25% Foreign-Owned U.S. Corporation or a Foreign Corporation Engaged in a U.S. Trade or Business.

On the other hand, a foreign corporation that engages in business in the United States might not qualify as a reporting entity. This depends on whether or not the foreign corporation has established relevant tax treaties and a permanent residence within the United States. It is important to remain aware of the transfer pricing penalties involved if your corporation operates in multiple countries.

California EDD

The California Employment Development Department (EDD) governs unemployment insurance in the state. Businesses throughout California are obligated to account for, hold, and submit payroll tax receipts to the EDD and other government entities. Penalties for failing to provide these receipts can be steep, including personal liability on the part of the company owner or the person responsible for these receipts.

The classification of employees can be a challenging aspect of employment law that many employers mishandle. The Los Angeles tax lawyer at Abajian Law understands how misclassifying an employee can lead to serious tax implications. An employer will suddenly be required to pay withholdings, self-employment tax, or other penalties if an employee is classified incorrectly or if the employer reclassifies the worker as a contractor or employee.

If a business is audited by the EDD, it will be a long, difficult process. When the audit begins, the business will be toured by a representative from the EDD and include an in-person interview. Informal interviews of the persons providing the tour might also be conducted by the EDD agent.

The most common triggers of an EDD audit include the following:

  • Inappropriate use of corporate funds
  • Use of structured transactions
  • Excessive cash transactions

All businesses no matter the industry in which they operate must be able to provide the sources for the cash they hold. If you are unable to provide these records, your business could not only be subjected to an audit by the EDD but also a federal employment tax audit by the IRS.

Businesses should keep the following documents for at least four years in the event that a business sales tax audit is conducted by the California Board of Equalization:

  • Register receipts whether electronic or paper
  • Cash receipts
  • Invoices
  • Bills
  • Schedules used in the preparation of tax returns

Los Angeles Office

When you are in need of a Los Angeles tax lawyer, you can put your trust in the experienced team at Abajian Law. Our Los Angeles office is located at 1999 Avenue of the Stars, Suite 1100, Los Angeles, CA 90067. You can contact our Los Angeles office by phone at (323) 990-8515 to schedule a consultation.

Contact a Los Angeles Tax Lawyer Today to Schedule a Consultation

Do you have questions about state, local, or federal tax laws? Has your business received a letter from the IRS about an audit or other tax issues? If so, it is in your best interest to speak with an experienced Los Angeles tax lawyer about your case. Abajian Law has experience working with individuals and companies of all sizes when dealing with tax controversies and the IRS. Call our office at (818) 396-5059 to speak with a member of our team today.

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