Philip Falco provides unfiled returns prep and strategy, international tax strategy and compliance, audit representation, expert in-house tax preparation, and expert tax strategy & planning.
Licensed: CPA License No. 31317 (est. 2013) · Colorado Bar No. 27930 (est. 1997). He graduated with honors, Cum Laude, from Law School in 1994. He passed the CPA exam in one sitting in 1991. If you want the very best, you have come to the right place. About Philip Falco here. Also, read about what makes us different here.
Schedule a $500 Tax Attorney Consultation to discuss your tax matter. The fee includes up to one hour of attorney time for review, analysis, preparation and the telephone consultation combined.
Tax Law and Tax Accounting Under One Roof
Many tax matters do not fit neatly into either a law office or an accounting firm.
An IRS examination may begin with accounting records but develop into a legal dispute. An unfiled-return matter may require years of tax preparation while also raising questions about penalties or willfulness. International reporting can involve highly technical forms as well as substantial civil or criminal exposure.
The practice combines the two disciplines rather than requiring clients to coordinate separately between an attorney and CPA.
Tax Preparation and Strategic Tax Planning
As both a tax attorney and CPA, Philip Falco can coordinate tax return preparation with the legal, business, and planning issues that often affect a client’s overall tax position. See Tax Preparation and Planning for Entrepreneurs and High Net Worth Individuals
For individual, business, partnership, S corporation, landlord, and other tax return services, see Denver Tax Preparation & Strategic Tax Planning.
Unfiled Tax Returns and Voluntary Disclosure
Unfiled Tax Returns: Unfiled Tax Returns Information. This is one of our specialties. We represent you before the IRS and prepare your returns (in house).
Falling behind on tax returns is more common than many taxpayers realize. The important question is how to come back into compliance correctly.
There is no general IRS amnesty program that simply forgives years of unfiled returns. In ordinary cases, the solution may involve reconstructing records, obtaining IRS transcripts, preparing the required delinquent returns, and addressing the resulting tax liability.
Cases involving deliberate non-filing, concealed income or assets, offshore accounts, or other potentially willful conduct require a different analysis.
Filing delinquent returns and making a formal IRS voluntary disclosure are not the same thing.
Taxpayers concerned about possible willfulness or criminal exposure should evaluate those issues before simply sending delinquent or amended returns to the IRS.
Unfiled Tax Returns |
IRS Voluntary Disclosure Practice
IRS Audits, Penalties and Tax Collection
Tax Audits: We have successfully handled many, many audits. We handle all audits including IRS full audits, Department of Labor, Department of unemployment, sales tax and others. Additional info on our site: Pre-Audit Investigations, IRS Audit Information, Audit Letters
An IRS problem can progress from a notice to an examination, assessment, and ultimately enforced collection.
Representation may involve challenging the underlying tax liability, responding to an audit, requesting penalty relief, negotiating payment arrangements, or addressing IRS collection action.
The appropriate strategy depends on where the taxpayer is in that process.
We have extensive audit experience:
- IRS Revenue Office audits
- Colorado Department of Revenue audits and issues
- Colorado Department of Labor and Employment Audits
- Federal Unemployment audits
- Sales Tax audits and compliance
IRS Audits |
Penalty Abatement |
Installment Agreements |
Offer in Compromise |
Bank Levy Release
International Tax and Foreign Reporting
U.S. taxpayers can have reporting obligations even when they live overseas, own foreign businesses, receive foreign gifts, or hold investments outside the United States.
International reporting problems can also carry penalties that are dramatically disproportionate to the amount of tax involved.
Philip Falco advises and represents taxpayers concerning:
- FBAR / FinCEN Form 114
- Form 8938 — FATCA
- Form 8621 — PFICs
- Form 5471 — Foreign Corporations
- Form 8865 — Foreign Partnerships
- Form 3520 — Foreign Gifts and Trusts
- Form 3520-A — Foreign Trusts
- Form 8858 — Foreign Disregarded Entities
- Delinquent International Information Returns
- Streamlined Filing Compliance Procedures
- IRS Voluntary Disclosure Practice
- International Taxation is one of our specialties. We keep US reportable persons in compliance by coordinating international tax treaties, and preparing appropriate foreign tax forms. We have vast experience with taxpayers who are not in compliance with foreign filings such as the FBAR. We specialize in the Streamlined Domestic Offshore Program.
- We launched an FBAR filing service to keep taxpayers with foreign “accounts” compliant.
- Our historical 2014 article on “Willful” Failure to Disclose Foreign Accounts on October 12, 2014.
- We have handled disclosures from around the world including but not limited to: Swiss (Switzerland) Bank Accounts, Cayman Islands, Channel Islands, and European Union.
We work with U.S. taxpayers and others facing U.S. tax issues regardless of where they are located.
Explore International Tax Services
WHY DUAL-LICENSED MATTERS
Philip Falco combines legal and financial analysis. You save money and receive advice that can benefit you for years to come. Many businesses and individuals seek his advice to set their tax and financial foundation. For example, entity selection, first year tax returns for s corp, partnerships, first year tax returns for foreign assets and accounts.
Most tax attorneys hand the tax and accounting work off to a CPA. Most CPAs limit their scope to numbers and avoid legal hot topics. Enrolled agents are not even required to have a University degree. General tax preparers and franchises are a disaster waiting to happen. As an attorney and CPA, Philip Falco brings legal and accounting analysis together in one office. That is not a marketing line. It is the specific reason clients with complicated, high-stakes situations choose to work with him.
Additional Services:
- IRS Defense: Criminal representation. As a licensed attorney, Philip Falco defends taxpayers. For example, we represent taxpayers during IRS collection matters, see also unpaid taxes.
- Last Will & Testament drafting, Trust drafting, master of the Rule against Perpetuities – Preserve wealth for 3 or more generations (create a dynasty).
- Asset Protection Trusts and Entities. See also Divorce Tax Planning.
- Sale of Business – Corporation, S Corp, Partnership or Sole Proprietorship. Also Real Estate transactions.
- Offers in Compromise, Penalty Abatement, IRS Levies, and Installment Agreements.
- FBAR FinCEN 114 filing service.
- We have a CFO Service
- Index of our extensive blog posts.
The art of the practice of Tax Law was endorsed in 1934 by Judge Learned Hand and can be summarized as follows: There is No Patriotic Duty to Pay More Tax than What is the Least Payable Under the U.S. Tax Code.
Over the years we have developed a number of specialties including representation of non-compliant taxpayers. We work on getting taxpayers into compliance with the Internal Revenue Service, the taxing state and local taxing authorities. We also represent taxpayers as an attorney during audits and other matters including criminal tax matters.
Philip Falco, Attorney, CPA – Your Colorado Tax Lawyer
730 17th Street, Suite 900
Denver, CO 80202
(303) 626-7000
Phil@coloradolegal.com
About Philip Falco, Attorney, CPA
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Tax Law Services and Resources
Colorado Legal provides attorney and CPA assistance with IRS disputes, tax debt, international reporting, business matters, real estate taxation and tax planning.