Michelle E. Espey counsels clients on a broad range of tax matters, from representing individuals and corporations at all stages of Federal, State and New York City tax disputes to advising clients on the tax aspects of various transactions. She regularly represents clients before the Internal Revenue Service, New York State Department of Taxation and Finance, New York City Department of Finance, and in the United States Tax Court.
Michelle has significant experience in federal and state audits; appeals and administrative protests, collection due process and equivalent hearing requests, and requests for penalty abatement. She assists non-filers in becoming compliant and provides counsel with respect to federal and state domestic voluntary disclosure programs. Michelle also assists clients with New York State and New York City residency planning; Trust Fund Recovery Penalty and Officer/Responsible person assessments; worker classification issues; sales and use tax planning and compliance; innocent spouse claims; and federal and state collections matters, including liens, levies, warrants, property seizures, offers in compromise, driver’s license suspensions; and negotiation of payment agreements.
Michelle represents individual U.S. taxpayers residing stateside and abroad in becoming compliant with their U.S. tax and information reporting obligations regarding foreign financial assets. She assists individuals with the IRS’s Streamlined Compliance Procedures, Delinquent FBAR Submission Procedures and Delinquent International Information Return Submission Procedures. Michelle helped countless individuals through the Offshore Voluntary Disclosure Program prior to the program’s termination in Fall 2018. She advises clients on FATCA compliance issues, information reporting and withholding obligations, and cross-border tax issues related to inbound transactions.
Michelle counsels nonprofit organizations on issues relating to compliance and tax-exempt status. She also represents clients before the Pension Benefit Guarantee Corporation on matters concerning pension plan terminations, minimum funding deficiencies, excise tax and statutory liens.