Complex Tax Controversy and Litigation Landscape: Strategies to Avoid Risks and Pitfalls
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Kathleen Agbayani is Of Counsel in the North American Tax Practice Group. She concentrates her practice on all aspects of federal tax controveries and tax compliance. She represents clients in all stages of proceedings before the Internal Revenue Service, including audits, appeals, collections, and litigation. Ms. Agbayani has extensive experience in advising clients on issues regarding the Internal Revenue Service’s Offshore Voluntary Disclosure Program and Streamlined Filing Compliance Procedures, foreign bank account reporting (FBAR) obligations,and the Foreign Account Tax Compliance Act (FATCA). She has represented hundres of U.S. taxpayers with undisclosed offshore bank accounts and assets. She has published articles regarding voluntary disclosures and speaks frequently on this topic. She also advises high net worth individuals on international tax planning.