Tax Controversy · International Tax

Tax disputes, handled by someone who has sat on the other side of the table.

AttorneyLicensed in California

Certified Public AccountantLicensed in California

Former IRS Appeals OfficerIndependent Office of Appeals

Representing individuals and businesses before the IRS and state agencies — in English and 中文.

The practice

As an Appeals Officer, I settled FBAR, international penalty, TFRP and CDP cases. Before that, I advised multinationals in KPMG's International Tax group. Now I bring both perspectives to my clients.

Practice Areas

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01IRS Audits & AppealsAudits, Appeals protests and representation, Collection Due Process hearings 02California Tax Disputes & AuditsEDD payroll tax audits and worker classification, FTB audits and residency planning, CDTFA sales and use tax 03Offshore Disclosure & FBARWillful and non-willful FBAR, Streamlined (SDOP/SFOP), FATCA 04International TaxCross-border disputes: foreign tax credits, CFC / Subpart F, GILTI, FDII, BEAT · Forms 5471, 5472, 8621, 3520 05Trust Fund Recovery PenaltyForm 4180 interviews, Letter 1153 protests and Appeals 06Information Return Penalties§ 6721 and § 6722 penalty abatement 07Form 8300 & Cash-Intensive BusinessesIRS Form 8300 audits and penalties for businesses that routinely receive cash 08Foreign Owners of U.S. Real EstateFIRPTA withholding and certificates · Forms 8288, 8288-A, 8288-B

About

Tongzhou Li
李同舟

California attorney and CPA. Former Appeals Officer, IRS Independent Office of Appeals. Former KPMG International Tax. J.D., M.B.A. U.S. Army veteran.

Licensed

Attorney (CA) · CPA (CA) · REALTOR®

Languages

English · 中文 (Mandarin)

Full biography