Matt maintains an extensive federal tax controversy practice in which he represents taxpayers in all stages of proceedings before the Internal Revenue Service, including examinations, appeals and collection proceedings. He regularly litigates cases in the United States Tax Court and other federal courts. He also represents clients in connection with highly sensitive so-called “eggshell” audits where indications of fraud may be present. In addition, Matt represents companies and corporate officers in connection with employment tax issues, including proceedings in which the IRS seeks to impose the Trust Fund Recovery Penalty on responsible corporate officers.

In addition, Matt frequently represents clients in connection with undeclared offshore assets, advising them as to their tax, FBAR and FATCA reporting obligations, and he has successfully guided hundreds of clients through various IRS voluntary disclosure initiatives, including the Offshore Voluntary Disclosure Program and the Streamlined Filing Compliance Procedures. Matt has published numerous articles regarding the IRS voluntary disclosure programs and FBAR and FATCA reporting obligations, and speaks frequently on these topics. He is the author of the Foreign Account Tax Compliance Act Answer Book (Practising Law Institute), a comprehensive guide to the due diligence, reporting, and withholding obligations imposed by FATCA on foreign financial institutions, non-foreign financial entities and withholding agents. Finally, Matt has represented numerous individual and corporate taxpayers in connection with the IRS domestic voluntary disclosure program and related state initiatives.

Representative Tax Controversy Matters

Matt has represented:

• Hundreds of taxpayers with undeclared bank accounts in Switzerland and other offshore jurisdictions seeking amnesty under the IRS Voluntary Disclosure Program and related IRS voluntary disclosure initiatives.
• An individual in IRS audit regarding offshore bank accounts and assessment of various penalties including FBAR, Forms 3520 and 3520-A, and civil fraud.
• Numerous foreign banks, investment advisors, and hedge funds located in Lebanon, Russia, Armenia, Cayman Islands, and United Kingdom as to their obligations under the Foreign Account Tax Compliance Act.
• A public company in a multi-year audit conducted by the IRS Large Business & International division.
• Numerous individual taxpayers in refund suits filed in the United States Court of Federal Claims and federal district courts.
• Construction companies and their owners in connection with IRS collection proceedings seeking unpaid employment taxes and assessment of the Trust Fund Recovery Penalty against responsible corporate officers.
• A real estate investor in Tax Court litigation claiming a foreign expropriation loss.
• An estate in Tax Court litigation involving disallowance of a substantial charitable contribution.
• A real estate developer in Tax Court litigation in a dispute regarding the appropriate method of revenue recognition.