When navigating complex tax matters, many individuals and businesses rely on professionals such as CPAs, enrolled agents, and tax preparers. While these experts are highly skilled in tax compliance and financial reporting, there are moments when a legal perspective is critical. In these instances, the insight of an LLM tax attorney—a lawyer with a Master of Laws in Taxation—can be the difference between compliance and costly mistakes.

At The Law Office of Pietro Canestrelli, A.P.C., we often collaborate with other tax professionals who seek specialized legal advice for their clients. Whether it’s a complex audit, estate planning, or international tax compliance, our firm helps ensure clients are fully protected from both a tax and legal standpoint.

What is an LLM in Taxation?

An LLM in Taxation is an advanced postgraduate degree for attorneys who want to specialize in tax law. This rigorous program goes beyond the basics taught in law school, diving deep into:

• Corporate and partnership taxation
• Federal and state tax controversies
• Estate, gift, and trust taxation
• International tax rules
• IRS administrative procedures

With this extensive training, an LLM tax lawyer is uniquely qualified to address legal ambiguities and defend clients in high-stakes situations.

Why Tax Professionals Consult with an LLM Tax Attorney

1. IRS Audits and Investigations

Tax professionals like CPAs can represent clients before the IRS in audits, but they cannot provide legal advice or representation in tax court. In serious audits—especially those involving fraud allegations or criminal exposure—an IRS audit attorney is critical.

An LLM tax attorney can:

• Offer attorney-client privilege
• Prepare legal defenses for IRS disputes
• File petitions in U.S. Tax Court
• Negotiate Offers in Compromise or payment plans

2. Complex Estate and Gift Tax Planning

Financial planners and CPAs often identify the need for estate tax minimization, but advanced techniques like GRATs, SLATs, or irrevocable trusts require legal drafting.

Our estate tax services help structure gifts and asset transfers in a way that ensures compliance while minimizing tax exposure.

3. International Tax Compliance (FBAR & FATCA)

When clients hold foreign bank accounts, trusts, or assets, they are subject to international reporting requirements. Missteps in filing FBAR or FATCA forms can result in six-figure penalties.

An international tax attorney can:

• Analyze and disclose foreign accounts
• Guide voluntary disclosure to avoid prosecution
• Coordinate with CPAs on dual-filing requirements

4. Business Restructuring & Tax-Efficient Entity Formation

Choosing between an S-Corp, C-Corp, partnership, or LLC has long-term tax and legal implications. While CPAs can offer general tax estimates, legal documentation and compliance rest with the attorney.

We provide support with:

• Business formation and restructuring
• S-corp elections
• Dissolutions and mergers
• Corporate tax planning

5. Tax Shelters and Promoter Penalties

If a client is involved in syndicated conservation easements, captive insurance schemes, or other potentially abusive tax strategies, both the client and advisor may be under scrutiny.

An LLM tax attorney helps assess:

• Legal risks in tax shelter participation
• Defense against IRS promoter penalties
• Compliance with anti-abuse rules

6. Bankruptcy and Tax Dischargeability

Tax professionals often lack the legal knowledge to advise whether a tax debt is dischargeable in bankruptcy. An LLM tax attorney evaluates whether the debt qualifies under the three-year, two-year, and 240-day rules.

Our tax relief attorneys work closely with bankruptcy counsel and CPAs to ensure optimal outcomes.

The Value of Attorney-Client Privilege

Only licensed attorneys can provide attorney-client privilege, a powerful tool that protects communication from disclosure. CPAs and EAs do not have this protection, putting sensitive conversations at risk of subpoena.

Especially during IRS fraud investigations or criminal tax cases, working with an LLM tax attorney ensures legal strategies remain confidential.

Signs It’s Time to Consult a Tax Attorney

Ask yourself these questions:

• Is the client facing an audit, notice, or legal dispute with the IRS?
• Is the situation beyond routine tax preparation?
• Is attorney-client privilege needed?
• Is there risk of litigation or criminal exposure?
• Are legal documents or court filings necessary?

If you answer yes to any of these, consulting an LLM tax lawyer is a smart next step.

Collaboration Benefits for CPAs and Advisors

The Law Office of Pietro Canestrelli, A.P.C. provides advisory services and co-counseling options to:

• Evaluate legal risk
• Draft tax strategy memos
• Represent clients in tax court
• Complement CPA advisory services with legal strategy

Explore our tax representation services to learn how we help clients and professionals navigate even the most challenging tax issues.

About The Law Office of Pietro Canestrelli, A.P.C.

Founded by a former IRS agent and tax attorney with an LLM in Taxation, our firm offers deep insight into IRS procedures and legal strategy. We work with clients throughout California and nationwide.

We routinely help:

• Individuals under audit or investigation
• Businesses needing restructuring or corporate tax advice
• Tax professionals seeking advanced legal guidance

Conclusion: Tax Law Is a Team Effort

Tax compliance isn’t always black and white—and when the gray areas arise, the best outcomes happen through collaboration. Whether you’re a CPA, EA, or financial advisor, partnering with an LLM tax attorney can elevate your practice and protect your clients.

If you’re facing a high-stakes issue or simply need strategic input, contact The Law Office of Pietro Canestrelli, A.P.C. today to schedule a confidential consultation.

We’re proud to be a trusted legal resource for California tax professionals and their clients nationwide.