Practice Area
Tax Dispute & IRS Representation
Expert defence for individuals, entrepreneurs and companies facing IRS audits, Italian Revenue Agency assessments, cross-border tax litigation and voluntary disclosure proceedings — protecting your rights on both sides of the Atlantic.
Received an IRS notice or Italian tax assessment? Response deadlines are strict — typically 30–90 days. Contact us immediately →
Who We Help
Are you facing one of these situations?
US Expat Under IRS Audit
American living in Italy who has received an IRS CP2000 notice, audit letter or collection notice — needing representation before the IRS from abroad.
Italian Taxpayer with Agency Assessment
Individual or company that has received an avviso di accertamento from the Agenzia delle Entrate or a processo verbale di constatazione from the Guardia di Finanza.
Delinquent Filer Seeking Compliance
US person who has not filed tax returns or foreign account reports (FBAR/FATCA) for multiple years and wants to come into compliance before being contacted by the IRS.
Cross-Border Business Under Investigation
Company facing simultaneous or coordinated tax investigations in Italy and the US — requiring a unified defence strategy that manages both jurisdictions in parallel.
01
IRS Audit Representation & Appeals
An IRS audit does not require you to speak directly with IRS agents. As enrolled attorneys and CPAs authorised to practice before the IRS, we represent you at every stage — from the initial examination through to the IRS Office of Appeals and, if necessary, the US Tax Court — protecting your rights and pursuing the best achievable outcome.
- Correspondence audit response: CP2000, CP3219A, Letter 531 and similar notices
- Office and field audit representation: Income, Schedule C, foreign income issues
- IRS Examination Division liaison: document production and issue management
- 30-Day Letter response and IRS Office of Appeals protest preparation
- US Tax Court petition drafting and settlement negotiation (Stipulated Decision)
- Collection Due Process (CDP) hearing representation for liens and levies
- Innocent Spouse Relief (Form 8857) for joint filers
02
IRS Streamlined Procedures & Voluntary Disclosure
US taxpayers who are behind on filing — whether returns, FBARs or information forms — have IRS-approved pathways to come into compliance with reduced or eliminated penalties. The Streamlined Foreign Offshore Procedures (SFOP) and Streamlined Domestic Offshore Procedures (SDOP) offer a structured route. For more serious non-compliance, the Voluntary Disclosure Practice (VDP) provides criminal penalty protection. We manage the entire process from eligibility analysis to submission.
- Eligibility assessment: SFOP vs SDOP vs Delinquent Procedures vs VDP
- Streamlined Foreign Offshore (SFOP): 0% FBAR penalty for non-willful non-residents
- Streamlined Domestic Offshore (SDOP): 5% miscellaneous offshore penalty
- IRS Voluntary Disclosure Practice (VDP): criminal protection for willful non-compliance
- Delinquent FBAR Submission Procedures and Delinquent International Information Returns
- Preparation of all amended returns, FBARs, Form 8938, 3520, 5471 and related forms
- Non-willfulness certification drafting and submission package management
03
IRS Penalty Abatement & Instalment Agreements
IRS penalties — failure-to-file, failure-to-pay, accuracy-related, and foreign information reporting penalties — can dwarf the underlying tax owed. The IRS has established relief mechanisms that many taxpayers are unaware of. We identify and pursue every available penalty abatement avenue, from First-Time Abatement to Reasonable Cause, and negotiate instalment agreements and Offers in Compromise for taxpayers who cannot pay in full.
- First-Time Abatement (FTA): automatic waiver for first-time compliance failures
- Reasonable Cause abatement: written narrative and supporting documentation
- FBAR civil penalty abatement: non-willful ($10K per violation) and willful ($100K+)
- Instalment Agreement (IA) negotiation: guaranteed, streamlined and partial-pay plans
- Offer in Compromise (OIC) under doubt-as-to-liability and doubt-as-to-collectibility
- Currently Not Collectible (CNC) status for taxpayers with hardship
- Lien subordination, withdrawal and discharge for property transactions
04
Italian Tax Litigation & Agenzia delle Entrate Defence
Italian tax assessments (avvisi di accertamento) can target income tax, VAT, IRAP, inheritance tax, foreign asset disclosures (Quadro RW) and transfer pricing. We provide full litigation support from the initial response to the Guardia di Finanza through to proceedings before the Corte di Giustizia Tributaria and the Supreme Court (Corte di Cassazione). Our cross-border expertise is particularly valuable when the Italian assessment involves foreign assets or cross-border transactions also subject to US scrutiny.
- Response to PVC (processo verbale di constatazione) by the Guardia di Finanza
- Accertamento con adesione: negotiated settlement with the Revenue Agency
- Acquiescenza parziale e totale: assessment of partial vs full acceptance strategy
- Ricorso to the Corte di Giustizia Tributaria di Primo e Secondo Grado
- Appello and Cassazione: higher-instance representation
- VAT and IRAP dispute management for Italian businesses
- Transfer pricing and CFC disputes: defence documentation and expert reports
05
Italian Voluntary Disclosure & Ravvedimento Operoso
Italian taxpayers who have failed to declare foreign assets, offshore accounts or foreign-source income face exposure to Quadro RW penalties (3–15% of undeclared assets per year) plus income tax and interest. Italy has periodically offered voluntary disclosure amnesties (Voluntary Disclosure 2015, 2016 and subsequent schemes). We advise on the current best route to regularisation — whether through ravvedimento operoso, spontaneous disclosure or structured settlement — to minimise the overall tax and penalty cost.
- Quadro RW regularisation: calculation of penalties, tax and interest due
- Ravvedimento operoso: spontaneous correction with reduced penalties (1/5 to 1/9)
- Analysis of statute of limitations (decadenza) for Italian assessments
- Offshore account and foreign asset regularisation strategy
- Coordination with Italian banking institutions for repatriation flows
- Interaction with parallel US Streamlined Procedures for dual-filing clients
- Criminal tax exposure assessment under D.Lgs. 74/2000 (dichiarazione fraudolenta)
06
Cross-Border Dispute Resolution & MAP Proceedings
When the same income or transaction is assessed by both the Italian and US tax authorities, double taxation can occur. The Mutual Agreement Procedure (MAP) under the Italy–US Tax Treaty (Art. 25) allows taxpayers to request that the two competent authorities negotiate a bilateral resolution. We prepare and submit MAP requests, coordinate with both authorities and advise on treaty-based double taxation relief to ensure the same income is not taxed twice.
- Mutual Agreement Procedure (MAP) request drafting under the Italy–US Treaty Art. 25
- Competent Authority submission to the IRS Large Business & International Division
- Italian Competent Authority submission to the Agenzia delle Entrate
- Bilateral Advance Pricing Agreement (BAPA) for ongoing cross-border transactions
- OECD BEPS Action 14 minimum standard: accelerated MAP resolution
- EU Dispute Resolution Mechanism Directive (2017/1852) for EU-resident taxpayers
- Transfer pricing corresponding adjustment: eliminating double taxation on TP adjustments
Our Approach
How We Handle Your Case
Immediate Assessment
We review your notice, assessment or situation within 24–48 hours, identify all deadlines and advise on the risk level and priority actions required.
Strategy & Defence Plan
We develop a written defence strategy: best case, realistic outcome, worst case — with a clear action plan, timeline and cost estimate before any work begins.
Authority Representation
We handle all communication with the IRS, Agenzia delle Entrate or courts. You are not required to speak directly with tax authorities — we represent you in full.
Resolution & Compliance
We negotiate the best achievable settlement, manage payment and ensure ongoing compliance to prevent recurrence — including amended filings and forward-looking planning.
Facing a tax dispute? Act before the deadline.
Response windows are short — typically 30 to 90 days. Our US–Italy dispute specialists will review your case, identify every available defence and represent you before the IRS or Agenzia delle Entrate.
