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Pedram Ben-Cohen Esq., CPA
Mindy Meigs Esq.
Lesley Sive Esq.
Negeen Ben-Cohen Esq.
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Pedram Ben-Cohen Esq., CPA
Mindy Meigs Esq.
Lesley Sive Esq.
Negeen Ben-Cohen Esq.
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FTB Notice – Excessive Expenses
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FBAR Case Summaries – Part 2
Table of FBAR Cases
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Publications / Press
Photos of Pedram Ben-Cohen, presentation at the 33rd Annual UCLA Tax Controversy Institute
Taxation of Transferring Funds From Abroad
Should Your Cannabis or Bitcoin Client Consider Taking the Fifth?
Offshore Bank Account Reporting and Compliance Options
IRS Finally Does The Right Thing! Huge Changes to the IRS Offshore Voluntary Disclosure Program
Key Provisions of the Foreign Account Tax Compliance Act (FATCA)
IRS Cracks Down on Unreported Overseas Accounts
Ben-Cohen Law Firm, Newsletter, IRS Cracks Down on Unreported Overseas Accounts
Treasury Department Circular No. 230
OFAC & The Iranian Sanctions Regime
Ben-Cohen Law Firm, Newsletter, New Safe Harbor For Like-Kind 1031 Exchanges
Common Tax Issues in a Down Economy, IRS Red Flags & Transactions in Property
Tax Issues in Bankruptcy and Insolvency Restructurings
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Practice Areas
Tax Audits
Federal Audits
State Tax Audits
FTB Notice – Excessive Expenses
Privileges and Protections
IRS National Research Program Audits
Tax Audits of Attorneys and Law Firms
Tax Audits of Cash Intensive Businesses
Criminal Tax Audits
Pleading the Fifth in an IRS Audit
Criminal Tax Defense
Reporting Cash Transactions
Tax Appeals
The Freedom of Information Act
Tax Litigation
Burden of Proof in Civil Tax Litigation
Refund Claims
Choice of Forum
Claim Preclusion and Issue Preclusion
Third Party Liability
Statute of Limitations
Statute of Limitations for Offshore Assets
Statute of Limitations for Tax Crimes
Voluntary Disclosures
2019 Relief Procedures for Former U.S. Citizens
Offshore Assets
Foreign Reporting Obligations
FBAR Case Summaries
FBAR Case Summaries – Part 2
Table of FBAR Cases
Penalties for Failure to File an FBAR
Employment Taxes
Trust Fund Taxes and Responsible Persons
Collection Defense
Residency Audits
Important California Residency Cases
Appeal of Bragg
Civil Tax Penalties
Innocent Spouse Relief