Telephone
02-77093611
Line
@fdlaw
address
17th Floor, No. 180, Section 2, Dunhua South Road, Da'an District, Taipei City
Professional business law firm specializing in tax planning and tax administrative relief
Fidelity Law Firm is a professional business law firm in Taiwan. The leading lawyer has served as the associate director of the legal department of the four major accounting firms. He has long-term cooperation with accountants to provide tax planning and relief procedures for listed companies and small and medium-sized enterprises, especially Specializing in estate planning and distribution, overseas tax planning, family offices, petitions and administrative litigation procedures.
Integration of tax lawyers and accounting practices
Tax disputes cannot be resolved by looking at just the tax law provisions; it also requires examining the accounts, vouchers, financial statements, transaction processes, and how the IRS determines the facts.
When businesses or individuals encounter tax audits, back taxes and penalties from the National Tax Administration, disputes over business tax, corporate income tax, income tax, inheritance tax, gift tax, tax reviews, appeals, or administrative litigation, they need tax lawyers who can simultaneously understand law, accounting, financial statements, and tax administrative procedures. The lead attorney at Fidelity Law Firm previously served as an assistant in the legal department of Deloitte Touche Tohmatsu, handling tax and corporate legal issues with accountants on a long-term basis—a key differentiator for our firm in tax disputes.
Tax lawyerTax audit by the National Taxation BureauTax refund and fineTax administrative remediesTax reviewAppealAdministrative litigationTax disputes of listed companies
Which tax issues require legal intervention?
When you receive documents from the IRS, tax penalties, or tax investigations, it is always beneficial to gather legal and accounting evidence as early as possible.
The IRS may conduct tax audits, adjust accounts, or request explanations.
When a company receives a notice from the IRS to adjust accounts, request additional documents, or be invited for a meeting or asked to explain the transaction process, it should first confirm the scope of the information, the legal basis, and the potential risks to avoid making unfavorable explanations before fully understanding the points of contention.
Disputes concerning back taxes, fines, tax evasion, or fraudulent transactions
Tax penalties are usually not just a matter of amount, but also involve tax collection laws, administrative penalties, intentional negligence, admissibility of evidence and authenticity of transactions. When necessary, assessment and review, appeals and administrative litigation may be required.
Disputes over business tax, corporate income tax, income tax and withholding
Common disputes include input tax credits, output tax recognition, revenue attribution, cost and expense recognition, related-party transactions, withholding obligations, and the substance of overseas income and transactions.
Tax Risks of Listed Companies, Directors and Supervisors, and Corporate Governance
Tax disputes involving large companies often involve financial statements, board resolutions, shareholder meetings, internal control systems, material information, directors’ and supervisors’ responsibilities, and securities laws, requiring a thorough understanding of both corporate governance and tax laws.
Inheritance tax, gift tax and high-net-worth arrangements
When planning family property transfers, equity succession, real estate arrangements, offshore assets, trusts, or family offices, tax, civil, inheritance, and company equity arrangements should be considered simultaneously.
Tax disputes may extend to criminal or commercial accounting liabilities.
If issues such as false documentation, tax evasion, fictitious transactions, commercial accounting laws, money laundering prevention, or liability of company executives are involved, a tax lawyer and a criminal lawyer should jointly assess the overall strategy.
Fidelity's tax and legal advantages
Previously served as Assistant Manager in the Legal Department at Deloitte Touche Tohmatsu, with extensive experience working with accountants and familiar with financial statements, National Taxation Bureau disputes, and corporate governance of listed companies.
Lawyers need to understand accounting and financial statements to grasp the core of tax disputes.
The key aspects of tax cases often lie in accounting classification, the authenticity of vouchers, revenue and cost recognition, related-party transactions, financial statement disclosures, and the substance of transactions. The lead attorney previously served as an assistant in the legal department of Deloitte Touche Tohmatsu, working extensively with accountants and becoming familiar with the communication language between accountants, corporate finance departments, boards of directors, and the IRS.
Tax Disputes and Corporate Governance Experience of Large Enterprises
Our firm has assisted in handling various tax and commercial disputes related to large listed companies, and has extensive experience in substantive adversarial proceedings, reviews, appeals, and administrative litigation with the National Taxation Bureau. Our lead attorneys also frequently participate in shareholder meetings and board meetings of listed companies, and have taught corporate governance courses to directors and supervisors, enabling us to assess tax disputes in conjunction with corporate governance and financial reporting responsibilities.
The biggest problem with tax cases is looking at them from only one perspective.A single tax penalty may involve contracts, invoices, accounting entries, financial statements, board resolutions, the substance of the transaction, administrative procedures, and litigation evidence. Our strength lies in integrating these aspects into an actionable treatment strategy.
Main tax legal services
From IRS audits to administrative litigation, we assist businesses and individuals in handling high-risk tax disputes.
Tax audits and investigation responses from the National Tax Administration
- Responses to Account Adjustment Notices, Request for Required Documents, and Interviews
- Transaction process, contracts, vouchers and accounting
- Explanation, statement of opinion and supplementary materials from tax authorities
- Assess whether there are administrative penalties or criminal risks involved.
Tax penalties and administrative remedies
- Review, Appeal, Administrative Litigation
- Disputes over business tax, corporate income tax, and income tax
- Inheritance tax, gift tax and property transfer disputes
- Suspension of execution, evidence collection and dispute analysis
Corporate Taxation and Corporate Governance
- Tax disputes of listed companies
- Financial Statements, Board of Directors and Internal Control System
- The Intertwining of Directors' and Supervisors' Liability with Corporate Legal Issues
- Corporate Governance Education and Training and Risk Assessment
Tax risks in transactions and investments
- Equity transactions, mergers and acquisitions and investment structures
- Related-party transactions and determination of transaction substance
- Foreign income, cross-border transactions and capital flows
- Contract terms and tax burden allocation
High-net-worth and family wealth arrangements
- Inheritance tax, gift tax and inheritance planning
- Equity succession, real estate and overseas assets
- Family Offices and Property Distribution Disputes
- Integration of tax, civil and family risks
Tax Criminal Risk Prevention Line
- Tax evasion, false documents and fictitious transactions
- Risks related to commercial accounting law and tax collection law
- Intertwined procedures involving prosecutors, the National Tax Administration, and anti-corruption efforts.
- Coordination of Criminal Defense and Administrative Remedies Strategies
Tax Dispute Review
Common Tax Issues and Their Handling Directions
Current situation
Materials that usually need to be organized
Recommended key points to focus on
Received IRS notification of account adjustment, supplementary documents, or explanation
Notification documents, ledgers, invoices, contracts, payment records, transaction details
First, determine the scope and issues of the information requested by the IRS to avoid providing unnecessary or poorly organized explanations, and establish the evidence required for subsequent reviews or litigation.
Received a notice of tax payment or fine.
Disciplinary notice, approval notice, date of delivery, tax calculation, reasons for penalty, and original application materials.
Confirm the statutory remedy period, assess the possibility of review, appeal, administrative litigation, and application for suspension of enforcement, and avoid missing the deadline.
Business tax, business income tax or income tax is deemed problematic
Purchase and sales invoices, cost and expense records, revenue recognition, withholding documents, and related party transaction information.
Examine the accounting treatment, the substance of the transaction, and the legal regulations to clarify whether there is room for supplementary taxation, whether the penalty can be disputed, or whether the liability can be mitigated.
Tax disputes involving listed companies may involve financial statements or the responsibilities of directors and supervisors.
Financial statements, board information, internal control systems, material information, and related documents from accountants' working papers.
Simultaneously assess tax disputes, corporate governance, securities laws, and the due diligence obligations of directors and supervisors to prevent tax disputes from escalating into corporate governance crises.
Disputes over inheritance tax, gift tax, or family property transfer
Property register, shareholding information, real estate information, gift records, wills or family agreements
Integrate planning from the perspectives of taxation, inheritance, corporate equity, and family governance to reduce the risks of future tax arrears, inheritance disputes, and administrative remedies.
Tax disputes may involve criminal liability
Transaction documents, invoice sources, cash flow, internal company decision-making and personnel division of labor information
Before providing explanations or accepting investigations, assess the tax collection law, business accounting law, and criminal risks to avoid administrative cases escalating into higher-risk procedures.
Processing flow
Tax disputes require simultaneous management of timelines, evidence, accounting entries, and legal points of contention.
Confirmation of documents and deadlines
First, examine the IRS documents, the disciplinary notice, the date of service, and the statutory period for relief to determine whether the case is currently in the investigation, review, appeal, or administrative litigation stage.
Organizing accounts and evidence
Work with accountants or corporate finance personnel to organize ledgers, vouchers, contracts, invoices, cash flow, financial statements, and transaction processes to identify discrepancies between the IRS's findings and the facts.
Develop relief and litigation strategies
Depending on the risks of the case, options include explanation, negotiation, review, appeal, administrative litigation, suspension of enforcement, or criminal defense, and arrangements should be made for the subsequent evidence and document processing.
FAQ
Frequently Asked Questions about Tax Lawyers
When should you consult a tax lawyer if you receive a tax audit notice or a penalty for tax payment from the National Taxation Bureau?
Upon receiving a tax audit notice, accounting adjustment notice, tax payment penalty notice, review decision, appeal decision, or administrative litigation document from the IRS, it is advisable to consult a lawyer familiar with tax administrative remedies as soon as possible. Tax cases often have time limits and also require the simultaneous organization of accounting vouchers, financial statements, contracts, transaction processes, and tax law disputes.
What are the differences between tax lawyers and accountants in tax disputes?
Accountants are typically familiar with tax filing, accounting, and tax calculations, while tax lawyers focus on legality, evidence, administrative procedures, reviews, appeals, and administrative litigation strategies. Major tax disputes often require collaboration between lawyers and accountants, addressing both the accounting facts and the legal issues at play.
Can a company file for administrative relief if it is required to pay back business tax, corporate income tax, or corporate income tax?
Yes, but the type of disposition, the date of service, the statutory period, the amount in dispute, the supporting evidence, and the reasons given by the tax authority must be confirmed first. Common procedures include review, appeal, and administrative litigation. If necessary, an assessment will also be made as to whether to apply for a stay of execution or to provide an explanation to the tax authority.
Why do listed companies or their directors and supervisors need lawyers who understand corporate governance when they encounter tax issues?
Tax disputes involving listed companies often involve financial statements, board resolutions, internal control systems, material information, directors' and supervisors' responsibilities, and accounting judgments. Lawyers with backgrounds in corporate governance and accounting firms are better able to assist companies in assessing tax issues, corporate law, and securities law risks together.
Could a tax case turn into a criminal case?
Some cases may involve criminal risks if they involve issues such as false documents, fictitious transactions, tax evasion, commercial accounting law, tax collection law, or anti-money laundering measures. It is recommended that you have a lawyer assess the documents and explain the direction and potential liabilities before accepting an investigation or providing any information.
What are the distinctive features of Fidelity Law Firm in handling tax disputes?
The lead attorney at Fidelity Law Firm previously served as the assistant legal manager at Deloitte Touche Tohmatsu, and has long collaborated with accountants. He is familiar with accounting, financial statements, shareholder meetings and board meetings of listed companies, corporate governance, and dispute resolution with the National Taxation Bureau, and can integrate strategies from tax, accounting, and litigation perspectives.
Are you currently dealing with an IRS tax audit, back tax payment, fine, or tax administrative remedy?
You can prepare the National Taxation Bureau documents, disciplinary notices, accounting information, invoices, contracts, financial statements and transaction records in advance. Our firm will arrange the assessment according to the tax and litigation stages.
02-7709-361117th Floor, No. 180, Section 2, Dunhua South Road, Da'an District, Taipei Cityinfo@fdlaw.com.twLine: @fdlaw