Hamersley Partners offers tax consulting and business advisory services to individual and corporate taxpayers, private equity and investment groups, CPA firms, and law firms, including but not limited to the following :

  • Transactional tax planning, tax due diligence, disclosure reporting, and tax issue analysis in the form of written memoranda and tax opinion letters regarding the  income tax consequences associated with a given business transaction or tax return position.
  • Representation of taxpayers in audits, closing agreements, settlement,  and other tax controversy matters before the IRS and state tax agencies (e.g., California's Franchise Tax Board (FTB) and Office of Tax Appeals (OTA)).
  • Litigation discovery, trial preparation consulting,  and expert witness testimony in civil claims  involving tax shelters, complex transactional tax matters,  and highly structured business and financial transactions.
  • Analysis and preparation of disclosure/reporting obligations and penalties relating to reportable transactions, corporate and partnership transactions, ownership and interests in foreign entities and bank accounts, etc. 
  • IRS and state tax agency tax liability resolution through offer in compromise, installment agreements, penalty abatement, etc.  
  • Mitigation of IRS and state agency collection actions such as tax liens, bank account levies, and wage garnishment.
  • Preparation and submission of advance rulings to the IRS and FTB to obtain guidance and certainty regarding the agency's treatment of a given business transaction and/or tax return position.