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Founder and Principal Attorney

Allie petrova

“I enjoy helping my crypto friends navigate the intricate world of crypto tax.
My passion lies at the intersection of law and numbers. The higher the stakes, the sweeter the wins.”

How Allie Can Help You

Experience

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Excellence

Recognized by Best Lawyers 2022
Rated by Super Lawyers
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What I do

Attorney Petrova handles crypto tax disputes before the Internal Revenue Service and in the U.S. Tax Court.

Attorney Petrova regularly advises on complex tax issues. A broad base of knowledge enables Allie to view a matter from tax, business, and financial perspectives. She has successfully conducted high-stakes negotiations the Internal Revenue Service.

Allie is a hands-on tax lawyer. She has personally used the trading platforms and exchanges for crypto transactions.

Experience

Ms. Petrova has sophisticated tax experience and tax law training. Allie’s experience incorporates tax work at the Internal Revenue Service and the headquarters of the Taxpayer Advocate Service, both in Washington, D.C.

Allie gained her sophisticated tax and transactional experience while advising on M&A tax projects at the headquarters of Ernst & Young in New York City where she worked on cutting-edge transactions. Mere steps from Times Square, Allie’s practice focused on complex tax structuring and planning for a wide range of domestic and international business transactions.

Allie hails with an advanced tax law degree from the Georgetown University Law Center, a top U.S. tax law program.

Allie’s cross-border experience spans across the Atlantic and enables her to connect the dots in business and legal activities abroad. Allie has worked at law firms in Brussels and Stockholm, has completed a summer program at the European Commission Headquarters. Allie also holds a bilingual law degree from La Sorbonne in Paris.

Most recently, Allie attended Permissionless held in West Palm Beach, Florida and Consensus 2022 held in Austin, Texas.

Admissions

U.S. Tax Court

U.S. Supreme Court

State Bar of New York

State Bar of North Carolina

Education

LL.M., Taxation, Georgetown University Law Center

LL.M., International Economic Law, La Sorbonne in Paris

J.D., Georgetown University Law Center

B.S., Business Administration and Economics, Greensboro College (magna cum laude; Wall Street Journal Award)

Recognition

Business North Carolina, Legal Elite, Tax/Estate Planning, 2018-2022

Super Lawyers, North Carolina, Taxation and Mergers & Acquisitions, 2019-2022

Best Lawyers in America®, Business Organizations; Tax Law; Tax Controversy and Litigation, 2021-2022

Nolan Fellowship, American Bar Association, Section of Taxation, 2020

Triad Business Journal, Forty Under 40, 2020

Attorney-Client Privilege

When you work with a tax attorney, you receive the protection of a high degree of confidentiality that is unmatched by other professional relationships. That is thanks to the attorney-client privilege. The privilege protects communications made in confidence to an attorney from disclosure to the government.

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Tax for DAOs and Investors

We assist with tax efficient investment. We assist with the design a corporate structure, domestic or cross-border, from a tax perspective.

  • Our practice is unique as we see tax issues from a 360 perspective. We are engaged in tax planning and design at the front end. On the back end, we assist with IRS examinations of tax positions and the resolution of the related tax liabilities and penalties. Working with us comes full circle.
  • We help develop legally compliant structures for DAOs and investors. We advise on avoiding unintended tax consequences.

Offshore Asset Reporting

We help clients evaluate their options and remedy previously undisclosed foreign crypto assets involved in trading on non-U.S. exchanges.

  • U.S. taxpayers have U.S. tax and information reporting obligations with respect to non-U.S. investments. Complexities and reporting obligations arise when non-U.S. investors participate in trading on U.S. exchanges.
  • We help crypto trader clients come in compliance when they are delinquent with filing the FBAR (Report of Foreign Bank and Financial Accounts) and the Form 8938 (Statement of Foreign Financial Assets). Filing of these information returns can help U.S. crypto traders and investors avoid serious penalties for not reporting these crypto assets. Omission to file may lead to severe penalties starting at $10,000.
  • We help crypto trader benefit from the Streamlined Filing Compliance Procedures to help non-willful U.S. and non-U.S. crypto traders come into tax compliance. We also assist with abatement of offshore tax penalties.

Proactive Tax Planning

Are you concerned that your prior year returns may get you in trouble because your cryptos weren’t reported properly?

  • The IRS has heightened enforcement and its focus on examinations of crypto tax transactions. Because this still is a developing area of the tax law, related tax issues involve uncertainties. Crypto traders who think strategically are wise to take a strategic tax planning approach.
  • We can help our crypto trader clients with positioning themselves for the current and future tax years. We can help avoid unintended consequences. Doing things right on the front end can ultimately result in savings of tax and penalties later on.
  • We advise on reporting and software implementation. Use of transaction history from the blockchain and exchanges causes significant problems, which these services pass on to the crypto trader to reconcile and classify. Your tax preparer typically does not engage in that reconciliation process and requires you to provide the bottom-line crypto capital gains and income amounts.
  • We assess audit risk and offer suggestions to reduce the risk. We analyze the IRS records and tax reporting on clients’ prior year tax returns. This also enables us to identify issues that may need to be remedied in prior years and going forward. We assess audit risk and offer suggestions to reduce the risk.
  • We can guide you on how to properly report your crypto gains and leverage your losses to lower your taxes.
  • If the IRS has already contacted you, then your situation is more serious. You would need to schedule a private consultation to evaluate the best course of action.

IRS Tax Debt Resolution

We assist clients in the crypto space with IRS audits, filing of required disclosures, appeals, and resolution of back taxes.

  • We negotiate with the IRS for a living. We can develop a solid strategy for our crypto trader clients.
  • Crypto traders with IRS tax debt have special needs. Typically, crypto trader clients find selling their crypto assets to pay taxes to be undesirable.

If you owe taxes, the IRS can impose a lien or levy until you pay the liability in full. That allows the IRS to seize your income or property and use it to satisfy your outstanding tax liability. IRS liens and levies can damage you and your business by causing you to lose assets and income, can injure your credit and your reputation, and can impact your ability to meet your other financial obligations.

  • Negotiate payment terms of Installment Agreements
  • Negotiate settlements through Offers in Compromise
  • Negotiate refunds and penalty abatements
  • Negotiate resolution of tax assessments with IRS Appeals
  • File petitions and defend claims in the U.S. Tax Court
  • Secure releases of wage and bank levies
  • Secure lien releases
  • If you owe taxes, the IRS can impose a lien or levy until you pay the liability in full. That allows the IRS to seize your income or property and use it to satisfy your outstanding tax liability. IRS liens and levies can damage you and your business by causing you to lose assets and income, can injure your credit and your reputation, and can impact your ability to meet your other financial obligations.

IRS Tax Audit Guard

Want to know well in advance if the IRS has flagged you for audit?

  • Our IRS Tax Audit Guard service is proactive about early detection.
    This program monitors for an early warning of an upcoming IRS audit.
  • We monitor your IRS account proactively and deliver to you status updates to flag potential concerns. We would inform you of any IRS debt, alert you if a return has underreported income, identify any liens on your file, and highlight any IRS audit activity. Our technology delivers information directly from the IRS databases.
  • You will receive notifications worthy of your attention only if and when issues arise. Typically, selection for audit would appear on an IRS account approximately a month or several months before the IRS sends out an IRS audit letter. With this service, you would receive a notification of prior year tax returns flagged for an IRS audit.
  • You can register for this service for yourself (as an individual filer of IRS Form 1040). You can also register for any of your business if your business files a separate business return (IRS Form 1120, 1120-S, 1065, 1041, and not on Form 1040 Schedule C). This service requires a 12-month subscription and authorization to access your IRS account.

Are you facing an IRS crypto tax audit?

Have you received an IRS letter?

IRS Tax Audit Defense

  • We provide expert representation before the IRS throughout the entire IRS audit, appeals process, all the way up to U.S. Tax Court. We handle the negotiations with the IRS and protect your legal rights proactively.
  • We bridge tax law expertise with hands-on knowledge of crypto transactions and calculations.
  • Once we take on your case, we review your records and develop a personalized audit plan. We negotiate directly with the IRS auditors on your behalf, so you wouldn’t have to interface with your IRS auditor.
  • We prepare the documents to submit to the IRS. We keep you informed of the status of your case and your options every step of the way.
  • Crypto tax audits are data and numbers driven. Recalculating crypto gains early on is the key to a strong audit defense. It also establishes a basis for potential refunds. We will recalculate your crypto gains and have an amended return prepared as needed.

Have you received an IRS letter?

Reserve a private consultation

Timing is everything. Don’t wait! Take steps to resolve the matter before things escalate. Let our experience work for you.

  • Crypto traders and investors face a high risk of an IRS audit. What can begin as a basic adjustment to an individual federal income tax return can lead into inquiries into crypto transactions and a multi-year IRS audit.
  • Now that most exchanges are required to deliver information reporting to the IRS, the risk of discrepancies and taxpayer under-reporting is higher. Because they do not report cost basis to the IRS, the gains reported to the IRS may appear inflated and significantly higher.
  • While CPAs are masters of tax return filing, very few CPAs have actually defended a client in a full-blown IRS audit. Even fewer have dealt with IRS audits of crypto transactions. Our firm has experience representing clients in complex situations before the IRS.
  • While IRS tax issues related to crypto transactions share similarities, every case has its own nuances and specifics. Our services are personalized to fit your specific circumstances.
  • If you have received an IRS letter or are in the middle of an IRS audit, schedule a consultation ASAP. We accept new clients on a selective basis.

First 5 Steps When You Receive IRS Audit Letter

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This free report maps out the first five (5) steps a tax attorney would recommend taking after receiving an IRS audit letter. Enter your email address to receive this report.

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Top 3 Crypto Tax Audit Risk Factors

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This free report identifies three (3) of the most significant factors implicated in IRS crypto tax audits. Enter your email address to receive this report.

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