Jeff Silver, JD,
CPA
As a tax attorney and CPA with more
than 20 years of experience, Jeffrey Silver has successfully advised
small and medium-sized businesses, business owners and high net
worth individuals in the practical, procedural and technical aspects
of domestic and international tax and business planning.
He provides planning strategies in
such areas as business formation and structure, sales and
acquisitions of closely-held businesses, like-kind exchanges, tax
attribute preservation for corporate acquisitions and
reorganizations, corporate separations, basis and at-risk rules for
flow-through entities, passive activity losses, wealth preservation
for high net worth individuals, related party transactions,
subsidiary liquidations, partnership dissolutions,
employee/independent contractor issues, installment sales, built-in
gains tax issues, personal holding companies, estate, trust and gift
taxation, discharge of indebtedness, alternative minimum tax,
multi-state issues and consolidated group taxation. He also proficient in
preparing tax returns for all individual, corporate, partnership,
trust and estate and gift tax filings.
Jeffrey Silver also has a particular
expertise with international tax planning, including strategies for
cross-border transactions (inbound and outbound), expatriate
taxation, taxation of foreign nationals in the U.S., treaty
analysis, FIRPTA, Subpart F, foreign tax credits, blocked income,
expatriate equalization, permanent establishment rules and the
various filing and disclosure requirements.
Further, he has extensive experience
in representing taxpayers in tax disputes with the Internal Revenue
Service, New York State, New York City, New Jersey, Connecticut and
various other taxing jurisdictions. He has successfully appealed
and/or negotiated hundreds of cases in connection with random tax
examinations, sales tax cases, state residency, hobby losses, state
and local allocations and apportionments, unreasonable compensation
and independent contractor matters. He has also successfully
negotiated Offers-in-Compromise and Deferred Payment Agreements for
taxpayers unable to satisfy their tax obligations.
Jeffrey Silver has been admitted to
practice before the United States Tax Court, allowing the
preparation and submission of Tax Court Petitions and arguments
before the Court.
Jeffrey Silver is a member of the NYS
Society of Certified Public Accountants (Member, International Tax
Committee; Member, Estate Planning Committee), American Institute of
Certified Public Accountants (Member, Tax Division), American Bar
Association, NYS Bar Association and the Nassau County Bar
Association (Member, Tax Law Committee). He has had articles
published and/or been quoted in various publications, including
Newsday, Long Island Business News, Business LI and The Nassau
Lawyer and is a member of various business groups, including LIEG,
LIBA, LeadPro and The Attorney Roundtable.
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