Tax Attorney in Greensboro, NC

A U.S. citizen or resident alien working abroad may exclude a portion of foreign earned income from U.S. tax under IRC §911. The 2026 exclusion amount is indexed for inflation and approaches $130,000 per qualifying individual. Two tests qualify: the physical-presence test (330 full days in a foreign country during any 12 consecutive months) or the bona-fide-residence test (an uninterrupted period that includes an entire tax year as a bona fide resident of a foreign country). Honda Aircraft staff who split time between Greensboro (PTI) and Kumamoto or Tokyo regularly fail the physical-presence test because the day-count is off. The exclusion is claimed on Form 2555 and requires Form 1116 foreign tax credit coordination for income above the exclusion. Errors on day-count records, tax-home determination, and treaty tie-breaker residency are the most common IRS audit triggers.

North Carolina applies a flat personal income tax of 4.5% for 2026 under N.C. Gen. Stat. §105-153.7, with a scheduled walk-down to 3.99% by 2027 under the enacted reductions in the 2023 state budget package. The flat structure means no progressive brackets — a Volvo Trucks engineer earning $150,000 and a Coca-Cola Consolidated executive earning $750,000 face the same marginal rate. North Carolina is also the only state with a corporate income tax rate (currently 2.5% under N.C. Gen. Stat. §105-130.3) that is scheduled to phase down to zero by 2030 — the lowest among states that still have a corporate income tax. This makes the relative federal exposure even more important — with a small state tax bill, federal IRS resolution is where most of the controversy work sits.

The U.S. Tax Court holds Greensboro trial sessions at the L. Richardson Preyer Federal Building and U.S. Courthouse, 324 W Market Street, Greensboro NC 27401. Greensboro is a designated Tax Court trial city, which means a petitioner residing in the Piedmont Triad can designate Greensboro on the petition under Tax Court Rule 140 rather than route to Winston-Salem or another out-of-county venue. Sessions are scheduled on rotation rather than monthly. Small-tax-case procedure under IRC §7463 is available for deficiencies of $50,000 or less per year and uses simplified evidentiary rules.

If you are a U.S. person (citizen, green-card holder, or resident alien meeting the substantial-presence test) and the aggregate balance of all your foreign financial accounts exceeded $10,000 at any point in the calendar year, you must file FinCEN Form 114 (the FBAR) by April 15 with an automatic extension to October 15. The threshold is aggregate across all accounts — not per account. A Japanese bank account, a Japanese securities account, and a small Japanese savings account together push you over the line. Non-willful penalties run up to $10,000 per violation per year under 31 USC §5321(a)(5); willful penalties run to the greater of $100,000 or 50% of the account balance at the time of violation. Form 8938 may also apply under IRC §6038D at higher thresholds. The Streamlined Domestic and Foreign Offshore Procedures provide a non-willful path to compliance with reduced or no penalties.

Under N.C. Gen. Stat. §105-241.6, NC DOR generally has three years from the later of the return due date or the actual filing date to assess additional tax. The period extends to six years for substantial omissions (more than 25% of gross income unreported), is unlimited where no return was filed, and is unlimited for fraud. Collection actions on assessed taxes run on an extended period under N.C. Gen. Stat. §105-242, and docketed judgments extend the collection horizon further. The federal IRS Collection Statute Expiration Date (10 years from assessment under IRC §6502) runs independently.

Yes. A wage levy under IRC §6331 reaches wages, salaries, and other amounts payable to the taxpayer in continuous fashion until released. Once Volvo Trucks N.A., Mack Trucks, FedEx, Coca-Cola Consolidated, Honda Aircraft, Cone Health, or any other employer's payroll department receives a CP90 or LT11 levy, it withholds amounts above an IRS exemption table allowance — which is calculated from filing status and dependents and is often quite small. Wage levies do not have the 21-day hold that bank levies have under IRC §6332(c); the employer remits each pay cycle. A properly-filed CDP request, an accepted IA, CNC status, or an accepted OIC stops the levy — but timing matters because each missed pay cycle is gone.

Probably yes for the federal trust-fund portion. IRC §6672 assesses a Trust Fund Recovery Penalty against any "responsible person" who "willfully" failed to pay over withheld taxes — the FICA and federal income-tax withholding portion of Form 941. The IRS conducts a Form 4180 interview to identify responsible persons. Anyone with check-signing authority, payroll-decision authority, or knowledge of the unpaid taxes can be assessed personally — that means founders, head-of-finance, and even a controller in certain fact patterns. For Greensboro restaurants, contract-manufacturing operations, hosiery shops, and small services entities, this often catches multiple people because cap-table authority and check-signing authority overlap. On the state side, NC DOR responsible-person liability under N.C. Gen. Stat. §105-242.2 operates on similar principles for entities that collect withholding and sales tax in trust.

The IRS Streamlined Filing Compliance Procedures provide a non-willful path back into compliance. Two tracks: the Streamlined Foreign Offshore Procedures (for filers physically outside the U.S. at least 330 days in one of the three prior years) and the Streamlined Domestic Offshore Procedures (for filers inside the U.S.). The Domestic version requires filing three years of amended returns plus six years of FBARs and pays a 5% miscellaneous offshore penalty on the highest year-end aggregate balance of unreported foreign accounts. The Foreign version waives the 5% penalty entirely. Greensboro's Vietnamese, Sudanese, Cambodian, Montagnard, and Hispanic-American communities resettled here through Lutheran Family Services and other refugee programs frequently retained home-country accounts that crossed the $10,000 threshold without realizing the U.S. reporting obligation. The Streamlined certification of non-willfulness is the critical document — the IRS scrutinizes it for facts that suggest willful conduct.

Yes. IRC §7345 authorizes the IRS to certify "seriously delinquent" tax debt — currently $62,000 for 2026, indexed for inflation — to the State Department, which may then deny passport renewal or revoke an active passport. The certification reverses when the debt is paid, an IA is in place, an accepted OIC is in force, an active CDP hearing is pending, or Innocent Spouse Relief is in process. Honda Aircraft engineers traveling between Greensboro and Japan, FedEx pilots on international routes, Volvo Trucks executives traveling to Sweden, and academic researchers at N.C. A&T and UNCG attending conferences abroad face real revocation exposure. Decertification typically processes within 30 days once a qualifying resolution is in place.

Federal tax-resolution fees vary by matter complexity. A straightforward Installment Agreement typically falls between $1,500 and $3,500. A full Offer in Compromise with Form 433 financial analysis runs $4,000 to $7,500. Audit defense depends on the audit type and the number of issues. A U.S. Tax Court petition with case workup and trial preparation generally starts at $6,000 and rises with case complexity. An expatriate engagement combining Form 2555 reconstruction, FBAR back-filing under the Streamlined program, and treaty tie-breaker analysis runs higher because it involves multiple form sets and foreign-document reconciliation. VTL provides a written fee quote after the free consultation. Cal Bar Rule 7.1 prohibits comparisons claiming we are cheaper or faster than competitors without verifiable substantiation, so we do not market on price.

Yes. Communications between you and a licensed attorney for the purpose of seeking legal advice are protected by federal common-law attorney-client privilege, subject to the usual exceptions (crime-fraud, waiver, third-party presence). The narrower federally-authorized tax practitioner privilege under IRC §7525 applies to non-attorney CPAs and EAs but does not extend to criminal-tax matters or to written tax-shelter communications. An attorney handling your tax case retains the broader privilege that survives criminal investigation, which matters significantly if a civil audit shifts to a Criminal Investigation Division referral — a real risk in undisclosed foreign-account fact patterns.

A Tax Court trial is a bench trial — no jury — before a Judge or Special Trial Judge of the U.S. Tax Court. The session opens with calendar call where the Court hears scheduling and motion issues. Most cases on the calendar settle before trial; the IRS Office of Chief Counsel attorney for the case meets with petitioner's counsel during the days before trial. If trial proceeds, the petitioner generally bears the burden of proof, presents evidence and witness testimony, and the Court issues a written opinion typically within several months after trial. Small-tax-case procedure under IRC §7463 applies to deficiencies of $50,000 or less per year per period and uses simplified evidentiary rules.

Yes, generally. IRC §6331(k)(1) suspends levy action while an offer is pending and for 30 days after a rejection, plus during any timely-filed Appeals review of a rejection. The IRS will not levy on you while a processable OIC is being evaluated. However, the IRS may still file a Notice of Federal Tax Lien during the OIC pendency to protect its position — the lien is not a levy. CSED is also tolled during pendency, which can matter when the original ten-year clock is close to expiring. A poorly-prepared OIC that gets returned (not rejected) does not provide the same protection — processability matters, and Forms 433-A(OIC) and 433-B(OIC) must be technically complete.

For administrative work at the NC Department of Revenue — informal review, audit response, payment plans, and Offer in Compromise filings — taxpayers may be represented by an attorney, a CPA, or another authorized representative under NC GEN-58 Power of Attorney rules. VTL handles this state-administrative work remotely alongside the federal-IRS side. For contested-case hearings at the NC Office of Administrative Hearings under N.C. Gen. Stat. §105-241.15, taxpayers may represent themselves or use authorized counsel. For judicial review at the NC Business Court Greensboro Division or the NC Court of Appeals, an attorney admitted in North Carolina is required — VTL refers those proceedings to North Carolina-licensed counsel and remains engaged on the federal-IRS side. Many NC DOR disputes resolve at the administrative or OAH stage without ever reaching state court.