Trusted Counsel.
Strategic Advocacy.

Aggressive representation at every stage of a tax dispute.

When the IRS or a state taxing authority comes calling, you need counsel who knows the process from the inside. The Karam Firm provides skilled representation through every phase of a tax controversy — from the initial audit notice through administrative appeals, Tax Court, and federal district court litigation — working to resolve matters efficiently and on the most favorable terms possible.

Representative Services

• IRS audit representation (correspondence, office, and field)

• IRS Independent Office of Appeals

• U.S. Tax Court litigation

• Federal district court and Court of Federal Claims

• Collection Due Process (CDP) hearings

• Offers in Compromise and installment agreements

• Penalty abatement and reasonable cause arguments

• State tax audit defense and administrative appeals

Who We Serve

Individuals and businesses facing IRS or state tax audits, assessments, collection actions, or tax litigation who need experienced counsel to protect their rights and minimize exposure.

Authoritative written analysis to support your positions and manage risk.

A well-reasoned tax opinion from qualified counsel provides critical protection — establishing reasonable cause, reducing penalty exposure, and giving clients the confidence to proceed with complex transactions. The Karam Firm also assists clients in obtaining private letter rulings and other guidance directly from the IRS when certainty is essential.

Representative Services

• Should-file and will-succeed opinion letters

• More-likely-than-not and substantial authority opinions

• Penalty protection opinions

• Transaction-specific tax opinions

• Private letter ruling requests

• Technical advice memoranda

• Closing agreement negotiations

• Reliance opinions for tax planning strategies

Who We Serve

Businesses, investors, and individuals undertaking complex transactions or tax positions who need authoritative written analysis or formal IRS guidance to support their reporting.

Comprehensive tax counsel across all jurisdictions.

Tax obligations do not stop at state or national borders. The Karam Firm provides integrated federal, state, and international tax advice — helping clients understand their obligations, structure transactions efficiently, and stay compliant across every jurisdiction in which they operate or invest.

Representative Services

• Federal income tax planning and compliance

• Multi-state nexus analysis and compliance

• International tax planning (inbound and outbound)

• FBAR and FATCA compliance

• Foreign account and asset reporting

• Transfer pricing analysis

• Tax treaty planning and analysis

• Cross-border transaction structuring

Who We Serve

Individuals and businesses with federal, multi-state, or cross-border tax obligations seeking proactive planning and compliance counsel.

Navigating the complex tax treatment of litigation proceeds.

The tax consequences of a legal settlement or judgment can be significant — and are often misunderstood. Whether you are a plaintiff, defendant, or attorney, The Karam Firm provides clear, practical guidance on the tax treatment of settlement proceeds, structured settlements, attorney fee allocations, and related reporting obligations.

Representative Services

• Tax characterization of settlement proceeds

• Physical injury and emotional distress exclusions

• Punitive damages and interest taxation

• Attorney fee deductibility analysis

• Structured settlement tax planning

• Form 1099 and W-2 reporting compliance

• Employment settlement tax issues

• Pre-settlement tax planning for plaintiffs and defendants

Who We Serve

Plaintiffs, defendants, and their counsel seeking clarity on the tax treatment of settlement proceeds, judgments, and related attorney fees.

Expert guidance on the rapidly evolving tax landscape for digital assets.

Cryptocurrency and digital asset transactions create complex tax obligations that many taxpayers and advisors are unprepared to handle. The Karam Firm provides sophisticated counsel on the tax treatment of crypto transactions — from trading and mining to DeFi, NFTs, and hard forks — as well as representation in IRS crypto enforcement actions.

Representative Services

• Cryptocurrency gain and loss reporting

• Mining and staking income tax treatment

• DeFi and yield farming tax analysis

• NFT tax characterization and reporting

• Hard fork and airdrop tax treatment

• IRS crypto audit and enforcement defense

• Voluntary disclosure for unreported crypto income

• Crypto-to-crypto exchange tax analysis

Who We Serve

Investors, traders, miners, and businesses involved in cryptocurrency and digital assets who need expert tax guidance and compliance support.

Resolving tax debt and compliance issues before they escalate.

Unresolved tax liabilities and compliance failures can lead to liens, levies, wage garnishments, and — in serious cases — criminal referral. The Karam Firm helps individuals and businesses get compliant, negotiate with the IRS, and resolve outstanding tax debts through the most favorable available resolution.

Representative Services

• Currently not collectible (CNC) status requests

• Installment agreement negotiation

• Offers in Compromise

• Federal tax lien discharge and subordination

• Levy release and wage garnishment relief

• Trust fund recovery penalty defense

• Delinquent return filing assistance

• IRS Voluntary Disclosure Program (VDP)

Who We Serve

Individuals and businesses with outstanding IRS tax liabilities, unfiled returns, or collection actions who need experienced counsel to resolve their situation.

Tax-efficient structuring for your most significant transactions.

The tax consequences of a business sale, merger, or acquisition can dwarf all other transaction costs — making experienced tax counsel essential from the earliest stages of deal planning. The Karam Firm provides integrated M&A tax advice, helping buyers and sellers structure transactions to minimize tax liability and avoid costly surprises at closing.

Representative Services

• Asset vs. stock sale analysis

• Tax-free reorganization structuring

• Section 338 and 336(e) elections

• Purchase price allocation (Section 1060)

• Earnout and contingent consideration tax treatment

• M&A tax due diligence

• Representations and warranties tax issues

• Post-closing tax dispute resolution

Who We Serve

Business owners, buyers, private equity sponsors, and their advisors seeking experienced tax counsel for mergers, acquisitions, and business sales.

Expert guidance on the establishment and administration of QSFs.

Qualified Settlement Funds (QSFs) provide defendants and their insurers with a powerful tool for resolving multi-claimant litigation — allowing the transferor to take a tax deduction at the time of funding while claimants retain flexibility in structuring their recoveries. The Karam Firm advises on the establishment, administration, and tax compliance of QSFs.

Representative Services

• QSF establishment and court approval

• QSF tax compliance (Form 1120-SF)

• Transferor deduction planning

• Claimant allocation and distribution planning

• Structured settlement integration

• Attorney fee QSF planning

• Mass tort and class action QSF administration

• QSF termination and wind-down

Who We Serve

Defendants, insurers, and plaintiffs' counsel in multi-claimant litigation seeking to establish and administer a Qualified Settlement Fund.

Sophisticated counsel for pass-through entity tax matters.

Pass-through entities — partnerships, LLCs, LLPs, and S corporations — offer significant tax advantages but also present complex planning and compliance challenges. The Karam Firm provides sophisticated counsel on the formation, operation, restructuring, and dissolution of pass-through entities, as well as representation in disputes involving these structures.

Representative Services

• Partnership and LLC tax planning

• Operating agreement tax provisions

• Special allocations and substantial economic effect

• Basis and at-risk limitation planning

• Passive activity loss planning

• S corporation elections and compliance

• Built-in gains tax planning

• Partnership audit rules (BBA) representation

Who We Serve

Business owners, investors, and their advisors seeking sophisticated tax counsel for partnership, LLC, and S corporation matters.

Comprehensive tax counsel for mission-driven organizations.

Tax-exempt organizations face a unique set of tax obligations and compliance requirements — from initial exemption applications through ongoing reporting, unrelated business income, and private foundation rules. The Karam Firm provides comprehensive tax counsel to nonprofits, foundations, and other tax-exempt entities.

Representative Services

• IRS exemption applications (Form 1023/1024)

• Public charity vs. private foundation analysis

• Unrelated business income tax (UBIT) planning

• Private foundation excise tax compliance

• Intermediate sanctions and excess benefit transactions

• Form 990 review and compliance

• State charitable registration and compliance

• Tax-exempt bond financing

Who We Serve

Nonprofits, foundations, trade associations, and other tax-exempt organizations seeking expert tax counsel and compliance support.

Resolving worker classification disputes before they become catastrophic.

Worker misclassification is one of the most aggressively enforced areas of tax law — with exposure that can include back taxes, penalties, and personal liability for responsible parties. The Karam Firm represents businesses and individuals in IRS and state worker classification disputes, and provides proactive counsel to help clients structure their workforce relationships correctly.

Representative Services

• IRS worker classification audits (SS-8)

• Section 530 relief claims

• Voluntary Classification Settlement Program (VCSP)

• State employment tax classification disputes

• Retroactive reclassification defense

• Trust fund recovery penalty defense

• Independent contractor agreement review

• Workforce restructuring tax planning

Who We Serve

Businesses and individuals facing IRS or state worker classification disputes, or seeking proactive counsel to structure their contractor relationships correctly.

Experienced defense when tax matters turn criminal.

Federal tax crimes — including tax evasion, filing false returns, and failure to pay — carry severe consequences including substantial fines and imprisonment. The Karam Firm provides experienced defense representation in federal tax crime investigations and prosecutions, working to protect clients' rights and achieve the best possible outcome.

Representative Services

• Tax evasion defense (26 U.S.C. § 7201)

• Filing false returns defense (§ 7206)

• Failure to pay or collect tax defense (§ 7202)

• IRS Criminal Investigation (CI) representation

• Grand jury subpoena response

• Voluntary disclosure to avoid prosecution

• Sentencing mitigation

• Civil tax liability resolution alongside criminal defense

Who We Serve

Individuals and businesses under investigation by IRS Criminal Investigation or facing federal tax crime charges who need experienced criminal tax defense counsel.

Navigating the tax and legal complexities of third-party litigation finance.

Third-party litigation funding has grown rapidly — and with it, a host of unresolved tax questions for funders, plaintiffs, and their counsel. The Karam Firm advises clients on the tax treatment of litigation funding arrangements, including the characterization of funding proceeds, repayment obligations, and the tax consequences of funded settlements and judgments.

Representative Services

• Tax characterization of litigation funding proceeds

• Funder return tax treatment

• Plaintiff tax planning for funded litigation

• Attorney fee tax issues in funded matters

• Structured repayment tax planning

• QSF integration with litigation funding

• Disclosure and reporting obligations

• Cross-border litigation funding tax issues

Who We Serve

Litigation funders, plaintiffs, and attorneys involved in third-party litigation finance arrangements seeking clarity on the tax treatment of funding proceeds and returns.