Anthony practices in the areas of tax controversy, federal litigation, and international taxation. Anthony is one of a select group of tax litigators who has litigated FBAR penalty controversies and may be the only person who has ever successfully contested an FBAR penalty under the Administrative Procedure Act. Anthony has served as lead or co-counsel in federal district court and federal court of appeals cases throughout the United States involving tax controversies, employment tax controversies, SEC securities litigation, diversity controversies, and post-employment covenants not to compete (including the successful litigation in district court for the Northern District of Georgia proceeding of first impression adjudicating the enforceability of a forum select clause and covenant not to compete controversy. This case was named in the California Labor and Employment Bulletin as one of the top ten California Trade Secrets and Unfair Competition Developments in 2015).
Anthony has also served as lead counsel with respect to domestic and international client matters involving United States Tax Court proceedings (including issues in which motions where filed with the court to exclude Internal Revenue Service Criminal Investigators from trial and the exclusion of privileged documentary evidence), Internal Revenue Service criminal investigations, and Internal Revenue Service civil examinations. In the area of offshore compliance, Anthony has represented hundreds of clients in making a multitude of voluntary disclosures to the Internal Revenue Service.
Finally, Anthony advises U.S. businesses and individuals along with foreign based businesses and individuals in connection with international tax planning and global tax projects including intangible property migration, Foreign Investment in Real Property Tax Act (“FIRPTA”), subpart F planning, and cross-border transactions (including PFICs, foreign currency, transfer pricing, and income tax treaties).
A Closer Look at the Non-Willful FBAR Penalty, California Tax Lawyer, 2013
Can an OVDP Participant Set Aside a Closing Agreement on the Theory of Duress?, JD Supra, July 2014
The Qualified Quiet Disclosure: Operating Outside of the IRS Offshore Voluntary Disclosure Initiative, JD Supra, November 2013
Collection Due Process Hearings: Is it a Second Chance for Taxpayers to Litigate a Matter Previously Missed?, JD Supra, April 2013
The Government Shutdown- Great News for Some Taxpayers, JD Supra, October 7, 2013
What a Tax Attorney Can Do for You: Understand how Apple Inc. Legally Does Not Pay Income Tax, May 22, 2013
The State of California Seeks Back Taxes from Small Business Shareholders- Not So Fast, February 14, 2013
The Unintended Consequences of Section 1706: ebookpedia net, February 2010
Benefit Using the LLC: A.D. Kessler’s Creative Real Estate Magazine, March 2009
How Real Estate Investors Can Deduct Unlimited Losses, Commercial Property, January 2009
Should Holders of Swiss Offshore Accounts Rush to Confess to the IRS, San Francisco, Business Times, December 2008
Co-author of Charitable Contributions of Industrial/Commercial Property: Market Tax Benefits, Plus Bargain Sales Revisited Vol. 19, No. 5, The Real Estate Tax Digest, May 2001
Professional Development and Continuing Education Provided to Other Lawyers
Advanced Strategies for Challenging FBAR Penalties: Using Administrative Procedures Act in Defending Against Assessments, Strafford Webinar, July 26, 2017
Offshore Banking Disclosure Update, West Legal Education, Webinar, November 13, 2014
Captive Insurance, West Legal Education, Webinar, December 16, 2014
Tax Inversions: A Tax Saving Strategy for Corporations and What Calls for Reform Mean, West Legal Education, Webinar, November 15, 2014
- Captive Insurance, Webinar, West Legal EdCenter, Nov. 13, 2014
- Tax Inversions: Tax Savings Strategies for Corporations and What Political Calls for Tax Reform Mean, West Legal EdCenter, Aug. 2014
- Westlaw, Captive Insurance- Risk and Tax Advantages, December 16, 2014
- Westlaw, Corporate Inversions, November 15, 2014.