Anthony leads the firm’s work in federal and international tax litigation, and provides sophisticated tax planning advice. With 15 years in practice, an advanced degree in taxation, and prior experience with a major national accounting firm, Anthony has successfully resolved hundreds of serious tax matters for business owners and high net worth individuals, both in court and through negotiation with the IRS.
A seasoned trial lawyer, Anthony regularly serves as lead counsel for clients in U.S. Tax Court and other federal court proceedings throughout the country. Anthony has represented clients in matters at the audit, appeals and litigation levels. He also represents clients in voluntary disclosure cases and penalty disputes under the Bank Secrecy Act. This includes recent cases of first impression adjudicating penalties assessed against holders of foreign bank accounts.
Anthony has also handled IRS criminal investigation cases involving individuals and entities accused of schemes to defraud the United States of income taxes through the use of undeclared offshore bank accounts and other tax avoidance methods. In this capacity, he has defended against a wide range of allegations, including tax evasion, filing false tax returns, money laundering, and wire fraud.
In addition, Anthony has experience in a broad range of transactions involving U. S. persons and entities doing business overseas, and foreign individuals and businesses conducting business or acquiring property in the U.S. This work includes general international tax planning, subpart F income minimization, Check-the-Box planning, tax planning with foreign holding companies, tax treaty planning, as well as planning for the FIRPTA, the Foreign Investment in Real Property Tax Act.
Beyond taxation, Anthony has represented businesses and individuals in other federal litigation, including contract disputes, U.S. Securities and Exchange Commission enforcement proceedings, and a restrictive covenant case, which was recognized by California Labor and Employment Bulletin as a top 10 development in trade secrets and unfair competition in 2015.
Anthony presents educational seminars and publishes articles on federal and international tax litigation. He is admitted to practice in numerous federal courts, including U.S. Tax Court. Anthony is a federal tax attorney and is not a member of the California bar. He is licensed in the state of Florida. Anthony does not advise or represent clients regarding California state tax issues.