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Jeffrey Silver, JD, CPA Jeffrey Silver, is 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 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 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. He is also 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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