Mr. August has, for over 45 years, represented taxpayers in tax controversies and litigation involving U.S. federal income and transfer taxation. Having experience in tax transactional tax planning as well, he is frequently called upon by other law firms and accounting firms to render advise to their clients in tax controversies and litigation. His involvements in cases before the IRS and other taxing authorities including:
- Individual Tax Cases. Including Global High New Worth audits, reasonable compensation, debt versus equity, tax credit issues, innocent spouse claims, penalty abatements and defense of penalties based on reasonable cause. Tax treaty issues. State and local income tax controversies, administrative proceedings and litigation.
- Corporate Entity Tax Cases. Corporate income tax challenges including proposed assessments against the common parent of a consolidated group of corporations. Tax treaty issues.
- Pass Through Entity Tax Cases. Including drafting provisions for forming partnerships under the special centralized audit rule regime, admission of partner, termination of partnership.
- Bankruptcy Cases involving individual, corporate or partnership tax issues.
- Estate and Gift Tax Cases, representations of beneficiaries, estates and trusts in various estate and gift tax issues before the IRS, including valuation of interests in privately owned business and investment enterprises. Tax treaty cases involving wealth taxation. Application of the private foundation rules. Transferee and fiduciary liability issues.
- Trial and Appellate Cases. Represented Clients Before the United States Tax Court, Federal District Courts and The Court of Federal Claims. Has appeared before the Eleventh Circuit Court of Appeals and on behalf of the Tax Section of the Florida Bar before the United States Supreme Court, amicus curiae.
- Represents Clients in Sensitive Audits. That Have Risk of Criminal Investigation.
- Representation of Clients Before the Internal Revenue Service, Criminal Investigative Division.
- Representation Before the National Office of the Internal Revenue Service. Mr. August frequently is asked as to whether it is possible to obtain a favorable ruling from the Internal Revenue Service on a pending transaction as well as seeking late election or other form of equitable relief.
- Employment Tax Cases.
