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Tax Attorney in Redwood City, California
What this page covers
- Federal IRS, U.S. Tax Court, and California FTB / CDTFA / EDD representation for Redwood City taxpayers
- Oracle Corporation (500 Oracle Pkwy), Electronic Arts (209 Redwood Shores Pkwy), Box (900 Jefferson Ave), Equinix (1 Lagoon Dr), Informatica, and Stripe-proximity RSU / ISO / §83(b) / AMT / §1202 QSBS / §409A planning
- FBAR, Form 8938, Form 8621 PFIC, and Streamlined Filing for Indian-American (ICICI, HDFC, SBI), Chinese-American (Bank of China, ICBC, CCB), and Pacific Islander (ANZ, BSP, Westpac) accounts
- San Mateo County AAB Prop 8 decline-in-value appeals at 400 County Center (Sept. 15 deadline); Assessor at 555 County Center
- San Mateo County government employee CalPERS + §457(b) + §401(k) representation (county seat, 400 / 555 County Center)
- Stanford University faculty & post-doc §117(a)/(c) and §403(b) work; Sequoia Hospital / Kaiser RWC / Stanford Health Care 1099 physician stack
- Caltrain Peninsula commute §132(f) transit fringe; FTB residency audits on Peninsula exits to Austin / Reno / Boise
Federal IRS and California state tax representation for Redwood City taxpayers — from the Oracle Corporation global headquarters campus at 500 Oracle Parkway in Redwood Shores, the Electronic Arts campus at 209 Redwood Shores Parkway, the Box Inc workforce at 900 Jefferson Avenue, the Equinix data-center headquarters at 1 Lagoon Drive, Informatica, Kelly Engineering, the Imperva-legacy / Thales CPL team, the broader Peninsula tech corridor with Stripe and Roblox proximity, the Indian-American and Chinese-American tech-worker community with cross-border account exposure at ICICI / HDFC / State Bank of India / Bank of China / ICBC / CCB, the Pacific Islander community in North Fair Oaks and surrounding neighborhoods with ANZ / BSP / Westpac accounts, the San Mateo County government employee workforce at the county seat (400 County Center / 555 County Center), the Stanford University faculty and post-doc population commuting south to campus and Stanford Health Care, the Sequoia Hospital and Kaiser Permanente Redwood City medical workforce, the Sequoia / Carlmont / Woodside high-school district staff households, the Redwood Shores / Emerald Hills / Farm Hill / Mount Carmel / Roosevelt residential corridors, the Caltrain Peninsula commute economy from the Redwood City station at James Avenue, and the San Carlos Airport adjacency. Our California Bar-admitted attorneys appear at the IRS San Mateo Taxpayer Assistance Center at 977 South Claremont Street, the FTB San Francisco Field Office at 121 Spear Street, the CDTFA San Francisco District Office at 121 Spear Street, the San Mateo County Assessment Appeals Board at 400 County Center Redwood City, and U.S. Tax Court trial sessions at the Phillip Burton Federal Building, 450 Golden Gate Avenue, San Francisco.
By Amir Boroumand, Esq. — California Bar #269570. Admitted to practice before the United States Tax Court. Last Reviewed: .
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Redwood City taxpayers facing IRS collection, FTB assessment, CDTFA audit, FBAR exposure, or county AAB reassessment
If you live or work in Redwood City — the Oracle Corporation campus at 500 Oracle Parkway with the lakefront Redwood Shores towers, the Electronic Arts campus at 209 Redwood Shores Parkway, the Box Inc operation at 900 Jefferson Avenue, the Equinix data-center headquarters at 1 Lagoon Drive, the Informatica team, the Kelly Engineering operation, the Stripe spillover commute from South San Francisco, the Roblox-and-Peninsula-tech worker concentration, the Indian-American and Chinese-American tech-worker community with cross-border account exposure, the Pacific Islander community in North Fair Oaks and adjoining neighborhoods, the San Mateo County government workforce at the county seat (400 County Center Hall of Justice and 555 County Center Assessor / Treasurer-Tax Collector / Controller complex), the Stanford University faculty and post-doc households commuting south, the Sequoia Hospital and Kaiser Permanente Redwood City medical workforce, the Sequoia Union High School District / Carlmont / Woodside teacher households, the residential corridors of Redwood Shores, Emerald Hills, Farm Hill, Mount Carmel, Roosevelt, Friendly Acres, and downtown Redwood City, or the Caltrain Peninsula commute population from the James Avenue station — you sit on a Peninsula city of roughly 86,000 that doubles as the seat of San Mateo County with one of the densest concentrations of enterprise-software, gaming, and cloud-infrastructure employment in California. Each thread carries a different federal and California tax profile. This page walks through what Redwood City representation looks like in practice.
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Past results do not guarantee future outcomes. Each tax case is unique and turns on individual facts and IRS or FTB discretion.
Why Redwood City tax matters call for a California-licensed firm
Redwood City is the seat of San Mateo County and a Peninsula city of roughly 86,000 sitting between San Carlos to the north and Atherton plus Menlo Park to the south, with ZIP codes 94061 (west and Emerald Hills), 94062 (Emerald Hills and Farm Hill), 94063 (downtown, North Fair Oaks adjacency, and Friendly Acres), 94064 (PO Box), and 94065 (Redwood Shores). Connections to the broader Bay Area run US-101 north to San Mateo, Burlingame, and San Francisco; US-101 south to Palo Alto, Mountain View, and San Jose; I-280 west to Skyline and the SF coast; CA-84 east across the Dumbarton Bridge to Fremont and the East Bay; and Caltrain from the Redwood City station at James Avenue with frequent baby-bullet express service into San Francisco. The economy is built around several anchors. First, Oracle Corporation — the global enterprise-software and cloud-infrastructure company — has its world headquarters at 500 Oracle Parkway in Redwood Shores. The campus is among the most recognizable in Silicon Valley, with the lakefront tower complex, an executive workforce in the thousands, and a long history of equity-compensation, RSU, ISO, and §409A nonqualified deferred compensation programs for senior employees. Second, Electronic Arts, Inc. at 209 Redwood Shores Parkway is the publicly traded gaming company behind EA SPORTS FC / FIFA, Madden NFL, Battlefield, The Sims, Apex Legends, and Star Wars Jedi titles, with a substantial Redwood Shores engineering, creative, and finance workforce. Third, Box Inc — the enterprise content-management cloud company — sits at 900 Jefferson Avenue near downtown. Fourth, Equinix, Inc., the global data-center operator, runs its corporate headquarters at 1 Lagoon Drive in Redwood Shores. Other Redwood City employers include Informatica, Kelly Engineering, the Imperva legacy team now under Thales CPL, and the historical GoPro presence. The Stripe global headquarters at 354 Oyster Point Boulevard in South San Francisco and the Roblox headquarters in nearby San Mateo pull additional Peninsula tech residents into Redwood City. The residential corridor — Redwood Shores around the lagoon system, Emerald Hills off Edgewood, Farm Hill behind the high school of the same name, Mount Carmel, Roosevelt, Friendly Acres, Centennial, North Fair Oaks adjacency, Woodside Plaza, and the downtown core along Broadway and Middlefield — houses senior tech, gaming, and finance professionals, San Mateo County government employees, Sequoia Union High School District teachers, and the Pacific Islander community concentration in North Fair Oaks.
Victory Tax Lawyers, LLP is a California-licensed tax-law firm. Both managing attorneys — Parham Khorsandi, Cal Bar #266658, and Amir Boroumand, Cal Bar #269570 — are members of the State Bar of California in active standing and admitted to practice before the United States Tax Court. We represent Redwood City clients directly before the California Franchise Tax Board, CDTFA, EDD, and the California Office of Tax Appeals — no Power-of-Attorney workaround through out-of-state counsel, no referral chain.
On the federal side, U.S. Tax Court bar admission has nationwide reach. A Redwood City petitioner typically designates San Francisco as the place of trial under Tax Court Rule 140, with sessions held at the Phillip Burton Federal Building, 450 Golden Gate Avenue. The IRS San Mateo Taxpayer Assistance Center at 977 South Claremont Street, the FTB San Francisco Field Office at 121 Spear Street, and the CDTFA San Francisco District Office at the same Spear Street address handle the day-to-day administrative work for Redwood City residents. Redwood City's federal docket runs through the U.S. District Court for the Northern District of California — the San Francisco Division at the Phillip Burton Federal Building (450 Golden Gate Avenue) or the San Jose Division at the Robert F. Peckham Federal Building (280 South First Street) depending on case-assignment. We appear at all of these venues.
The sections that follow set out the practice areas, the venue map, settlement ranges from prior cases, the seven-step engagement process, and 21 FAQs answering what Redwood City taxpayers actually ask.
Your tax rights as a Redwood City taxpayer
Federal taxpayer rights sit in the Internal Revenue Code and IRS Publication 1. California layers its own protections through the FTB Taxpayer Bill of Rights at Cal. Rev. & Tax. Code Part 10.7 and parallel rights inside CDTFA and EDD. Redwood City property owners add Prop 13 base-year, Prop 19 parent-child, and Prop 8 decline-in-value protections at the San Mateo County Assessor.
Right to representation (federal)
Under IRC §7521(b)(2), an IRS examiner or collection officer must suspend an interview when you state you wish to consult an authorized representative. Form 2848 puts a tax attorney between you and the IRS for the rest of the matter — including the field RO who shows up at an Oracle Parkway office, an EA Redwood Shores cube, a Box Jefferson Avenue desk, an Equinix Lagoon Drive operations floor, or a residential address in Redwood Shores, Emerald Hills, Farm Hill, Mount Carmel, Roosevelt, or downtown.
Right to representation (California)
FTB Form 3520-PIT or 3520-BE appoints counsel before the Franchise Tax Board. CDTFA Form 392 covers sales-and-fuel-tax matters; EDD DE 48 covers payroll. Once on file, every notice routes to your attorney rather than your Redwood City address on Edgewood Road, Farm Hill Boulevard, Davit Lane, Twin Dolphin Drive, Marlin Avenue, or Broadway.
Right to Collection Due Process
A Notice of Federal Tax Lien (IRC §6320) or Final Notice of Intent to Levy (IRC §6330) opens a 30-day window to request a CDP hearing on Form 12153. A timely CDP request pauses federal collection and preserves Tax Court review — important on Oracle, EA, Box, and Equinix payroll-account levies during quarterly close periods, Stanford Health Care and Sequoia Hospital payroll levies, and residential bank-account levies on Redwood Shores and Emerald Hills accounts.
Right to U.S. Tax Court review
A Notice of Deficiency triggers a 90-day petition window under IRC §6213(a). Redwood City petitioners commonly designate San Francisco as the place of trial, with sessions held at the Phillip Burton Federal Building at 450 Golden Gate Avenue — roughly 26 miles north via US-101. Sacramento is an alternative where docket timing favors it.
Right to an FTB protest and OTA appeal
A Notice of Proposed Assessment from the FTB carries a 60-day protest window under Cal. Rev. & Tax. Code §19041. The Notice of Action that follows opens a 30-day appeal to the California Office of Tax Appeals under §19045. The OTA hears the matter as an independent tribunal — no longer the State Board of Equalization — with hearing rooms in Sacramento (400 R Street headquarters), Los Angeles (355 South Grand Avenue), and San Francisco. Video appearance is the practical option for most Redwood City matters.
Right to a federal OIC
Under IRC §7122, the IRS may accept less than the full liability where doubt as to collectibility, doubt as to liability, or effective tax administration justifies settlement. Filed on Form 656 with Form 433-A(OIC) or 433-B(OIC). The Reasonable Collection Potential math treats Redwood Shores lagoon-frontage equity, Emerald Hills view-home equity, Oracle and EA RSU positions, Box and Equinix stock holdings, and W-2 income from Peninsula tech employers differently than the patterns the IRS sees from Central Valley filers.
Right to a California OIC
FTB compromise authority sits at Cal. Rev. & Tax. Code §19443. CDTFA runs a parallel offer program under §6832. EDD compromise sits at Cal. Unemp. Ins. Code §1735 and adjoining sections.
Right to a Collection Statute (federal 10 vs. California 20)
IRC §6502 gives the IRS 10 years from assessment to collect. The California parallel under Cal. Rev. & Tax. Code §19255 runs 20 years — double the federal tail. Pull both transcripts before negotiating any Redwood City resolution.
How Victory Tax Lawyers helps Redwood City taxpayers
Federal & California Offer in Compromise
We file federal Form 656 with Form 433-A(OIC) under IRC §7122, and FTB Form 4905 PIT or BE with the parallel California financial under Cal. Rev. & Tax. Code §19443. The two reviews run on different Reasonable Collection Potential math. Redwood Shores lagoon-frontage equity, Emerald Hills hillside equity, Farm Hill and Mount Carmel home equity, Oracle and EA W-2 plus RSU positions, Box equity holdings, Equinix data-center compensation, and ICICI / HDFC / Bank of China foreign-account positions all need correct valuation before either filing.
Installment Agreements (IRS & FTB)
Streamlined IRS IAs under $50,000, Non-Streamlined IAs above with Form 433-F disclosure, and Partial Pay IAs under IRC §6159 running through the CSED. FTB parallel plans under Form 3567; CDTFA and EDD have their own structures. Oracle and EA employees carrying RSU vest underwithholding, Box and Equinix ESPP §423 balance shocks, Stripe-proximate engineers, and 1099 Stanford Health Care and Sequoia Hospital contracted physicians all need a structure that survives Peninsula income volatility.
Lien release and withdrawal
A federal NFTL under IRC §6321 and FTB State Tax Liens under Cal. Gov. Code §7170 attach to Redwood City real property and record with the San Mateo County Assessor-County Clerk-Recorder at 555 County Center, Redwood City. We pursue release after payment, certificate of discharge for sale or refinance, subordination on Redwood Shores and Emerald Hills refinances, and lien withdrawal under Fresh Start for IAs under $25,000.
Levy release (IRS, FTB, EDD)
Federal wage and bank levies under IRC §6331 stop with CNC, an accepted IA, OIC processing, or a timely CDP. FTB Earnings Withholding Orders under Cal. Rev. & Tax. Code §18670 and bank levies under §18670.5 release under analogous resolutions. Federal bank levies hold 21 days; FTB holds 10 business days — the shorter California window makes timing decisive on Oracle and EA payroll accounts, Box and Equinix operating accounts at First Republic, Mechanics Bank, and Heritage Bank of Commerce, and 1099 receivables for Peninsula contractors.
FBAR, Form 8938 & Streamlined Filing
For Redwood City's Indian-American, Chinese-American, and Pacific Islander communities with cross-border accounts at ICICI, HDFC, State Bank of India, Bank of China, ICBC, China Construction Bank, ANZ, Bank of South Pacific, Westpac, and Hong Kong-based banks, we file FinCEN Form 114 (FBAR) under 31 USC §5314, Form 8938 under IRC §6038D, and Form 8621 PFIC where Indian mutual funds, ULIP policies, PPF, Chinese mutual funds, or Pacific Islander pooled funds are held. The Streamlined Domestic Offshore Procedure (5 percent miscellaneous offshore penalty) and Streamlined Foreign Offshore Procedure (zero-penalty) cure non-willful exposure; the IRS Voluntary Disclosure Practice handles willful exposure. Penalty math under 31 USC §5321 reaches the greater of $100,000 or 50 percent of the account balance on willful non-filings.
Audit and exam defense
IRS correspondence, office, and field audits handled at the San Mateo TAC at 977 South Claremont Street and the SF TAC at 450 Golden Gate Avenue. FTB residency audits under Cal. Rev. & Tax. Code §17014 on Peninsula departures to Austin, Reno, Boise, and Coeur d'Alene. CDTFA sales-tax audits on downtown Broadway and Middlefield retail, Redwood Shores office-park ancillary retail, and Sequoia Station retail handled out of the CDTFA San Francisco District Office. EDD employment-tax audits on Peninsula contract workers and Redwood City independent contractors. FBAR examination defense coordinated separately under the IRS Large Business & International division.
Penalty abatement
Federal First-Time Penalty Abatement and reasonable-cause requests under IRC §6651. FTB waivers under Cal. Rev. & Tax. Code §19131 and §19132. Reasonable-cause for Redwood City filers affected by 2017-2019 SF Bay Area PG&E PSPS events, 2020 SCU and CZU Lightning Complex air-quality closures, COVID-era Peninsula office shutdowns, and serious illness or family bereavement.
AAB & Prop 8 decline-in-value appeals
Redwood City Prop 13 base-year values from 2020-2022 purchases often exceed the post-cooling market in Redwood Shores condos, Emerald Hills, Farm Hill, Mount Carmel, and downtown townhomes. We file the informal Decline in Market Value Reassessment with the San Mateo County Assessor at 555 County Center, Redwood City and the formal AAB application before the September 15 deadline at 400 County Center. Supplemental and escape-assessment appeals follow their own 60-day filing windows from the supplemental notice.
Twelve tax issues we handle for Redwood City clients
Federal and California state practice areas framed for matters that walk through the door from the Oracle Redwood Shores executive workforce, the EA gaming campus, the Box and Equinix engineering ranks, the Stripe and Roblox spillover, the Indian-American / Chinese-American / Pacific Islander community, the San Mateo County government employee base, and the residential neighborhoods of Redwood Shores, Emerald Hills, Farm Hill, Mount Carmel, Roosevelt, Friendly Acres, North Fair Oaks, and downtown Redwood City.
Oracle & EA RSU, ISO & AMT
Oracle HQ at 500 Oracle Parkway, EA at 209 Redwood Shores Parkway, Box at 900 Jefferson Avenue, and Equinix at 1 Lagoon Drive run on RSU and stock-option compensation. RSU vests withhold at the flat 22 percent supplemental rate under IRC §3402(g), undershooting California's 13.3 percent top bracket combined with federal 37 percent. ISO exercises trigger the AMT preference under IRC §56(b)(3) on the spread between strike and FMV; pre-public exercises produce substantial AMT in the exercise year with the §53 minimum-tax credit recoverable later. We file Streamlined or Non-Streamlined IAs, reset withholding going forward, and run the AMT analysis before exercise where the structure is still flexible.
Oracle §409A & §415 high-three retired pay
Oracle's executive compensation profile carries IRC §409A nonqualified deferred compensation plans with distribution-timing rules and 20 percent additional tax plus interest under §409A(a)(1)(B) on noncompliant distributions. The §415 limit caps defined-benefit accrual; high-three pay for retired Oracle executives flows through §415(b)(1)(A). FICA-tax timing on NQDC under §3121(v)(2) creates separate exposure on vesting versus distribution. We coordinate the §409A and §415 analysis with the federal and FTB tax position for Oracle senior employees and retirees.
§1202 QSBS (Box, Equinix, Stripe early)
Founders, early employees, and seed investors in Redwood City and Redwood Shores startups should run IRC §1202 Qualified Small Business Stock eligibility before any disposition. C-corp issuance, $50M gross-assets cap at issuance, qualified-trade-or-business test, and the five-year holding period each have to clear. The exclusion runs up to 100 percent of gain on post-September-2010 acquired stock, capped per issuer at the greater of $10M or ten-times-basis. California does not conform to §1202 post-2013 — the federal exclusion does not eliminate California tax on the gain.
EA §174 R&E + §41 gaming research credit
Electronic Arts at 209 Redwood Shores Parkway sits on top of the 2017 TCJA §174 mandatory R&E capitalization regime — five-year domestic and fifteen-year foreign amortization starting tax year 2022, with software development explicitly included under §174(c)(3). The §41 research credit overlays at 20 percent or the 14 percent ASC, with California's R&TC §17052.12 state-credit conformity at 15 percent. We represent individual employees and equity holders on K-1 flow-through and ESPP §423 positions coordinated with corporate research-credit elections.
FBAR & Form 8938 (ICICI, HDFC, SBI)
Redwood City's Indian-American community drives a recurring FinCEN Form 114 FBAR and IRS Form 8938 compliance load on ICICI Bank, HDFC Bank, State Bank of India, Axis Bank, Kotak Mahindra, PPF, and EPF accounts. Threshold: aggregate foreign accounts over $10,000 at any point in the calendar year triggers FBAR under 31 USC §5314. Indian mutual funds and ULIP policies trigger Form 8621 PFIC reporting under IRC §1297. We file Streamlined Domestic Offshore (5 percent penalty) and Streamlined Foreign Offshore (zero penalty) where exposure is non-willful, and the IRS Voluntary Disclosure Practice for willful exposure.
FBAR (Bank of China, ICBC, CCB)
The Redwood City Chinese-American community holds accounts at Bank of China, ICBC, China Construction Bank, Agricultural Bank of China, China Merchants Bank, and Hong Kong banks. Same FBAR and 8938 framework applies. Wrinkles: U.S.-China tax treaty Article 4 residency tiebreaker, §901 foreign tax credit on Chinese dividend and interest income, beneficial-ownership accounts in Shanghai and Shenzhen where a U.S. person holds signature authority, and Hong Kong's non-treaty status. We unwind through Streamlined Filing Compliance Procedures.
Pacific Islander FBAR (ANZ, BSP, Westpac)
The North Fair Oaks-adjacent Tongan, Samoan, and Fijian community in Redwood City holds accounts at ANZ Bank, Bank of South Pacific (BSP), Westpac Banking Corporation, Bank of Hawaii Pacific branches, and Pacific Commercial Bank. The same 31 USC §5314 FBAR threshold and IRC §6038D Form 8938 thresholds apply. Inherited family-land trust accounts in Tonga, Samoa, and Fiji are often held in collective family-trust structures where signature authority sits with multiple family members — the 31 CFR §1010.350(e) test still reaches the U.S. person. We file Streamlined Filing Compliance Procedures where exposure is non-willful.
San Mateo County employee CalPERS + §457(b)
San Mateo County government employees working at 400 County Center (Hall of Justice / Superior Court), 555 County Center (Assessor / Controller / Treasurer-Tax Collector / Clerk-Recorder), and the Sheriff and DA operations all participate in CalPERS plus a §457(b) deferred-comp plan and frequently a §401(k) supplemental plan. The §457(b) plan does not aggregate with the §403(b) or §401(k) limit, so dual-plan participation moves significant pre-tax dollars in late-career years. CalPERS state-tax treatment changes on relocation under 4 USC §114 Pension Source Tax Act.
Stanford faculty §117 & §403(b)
Stanford University faculty, lecturers, post-docs, and Stanford Health Care physicians living in Redwood City carry IRC §117(a) qualified-scholarship exclusion analysis on tuition/fees, with room/board/stipend taxable; §117(c) carving out required-services compensation; §127 employer-paid education ($5,250 limit); §403(b) Stanford Contributory Retirement Plan; and visiting-faculty H-1B / J-1 / O-1 treaty-residency tiebreakers under Form 8843 / Form 1040-NR sourcing. Post-doc 1099-NEC / W-2 mismatches recur.
Prop 8 AAB appeals (San Mateo County)
2020-2022 Peninsula appreciation pushed Prop 13 base-year values above the post-cooling market across Redwood Shores condos, Emerald Hills, Farm Hill, Mount Carmel, Roosevelt, and downtown Redwood City. The San Mateo County Assessment Appeals Board at 400 County Center handles Prop 8 decline-in-value appeals under R&TC §1603-1611 with a July 2 to September 15 filing window. Informal Decline in Market Value Reassessment is the no-fee preliminary path through the Assessor at 555 County Center; formal AAB application follows if the informal review does not produce the right number.
FTB residency audits (Austin, Reno, Boise exits)
Post-2020 remote-work exits from Redwood City to Austin, Houston, Reno, Las Vegas, Boise, and Coeur d'Alene pulled Oracle, EA, Box, Equinix, Stripe, Roblox, and tech-sector workers across state lines while many kept Redwood Shores condos and Emerald Hills homes. The nine-factor domicile test at R&TC §17014 puts those facts under FTB scrutiny. The Appeal of Bragg (2003), Appeal of Bindley (2018), and Corbett v. FTB line of authority frame the analysis. Deferred RSU vests and ESPP purchases after exit can still be California-source under Reg. §17951-5(b).
Trust Fund Recovery Penalty
Under IRC §6672, the IRS reaches owners of Redwood City LLCs and S-corps for unpaid payroll trust funds after Form 4180 interviews. EDD asserts the parallel state piece under Cal. Unemp. Ins. Code §1735. Common with downtown Broadway and Middlefield restaurant and retail operators, Sequoia Station inline-retail franchisees, Redwood Shores ancillary-retail tenants, and Peninsula contract-research startups. The criminal companion at IRC §7202 attaches to willful failures to collect or pay over.
Nine common causes of tax debt in Redwood City
1. RSU vest underwithholding at Oracle and EA
Federal employers withhold tax on RSU vests at the flat 22 percent supplemental rate. Senior engineers, product VPs, sales executives, and finance leads at Oracle (500 Oracle Parkway), EA, Box, and Equinix in California's top brackets owe an additional 15 to 20 percent come April. Prior-year balances roll forward into multi-year IAs.
2. ISO exercise AMT trap
Pre-public-offering and early-stage Peninsula employees who exercise Incentive Stock Options trigger AMT on the spread between strike and FMV under IRC §56(b)(3). The AMT can hit six figures in the exercise year even when no shares are sold — cash to pay must come from somewhere, and the §53 minimum-tax credit recovery runs out over future years subject to caps.
3. ESPP §423 ordinary-income shock
Oracle, EA, Box, and Equinix ESPP plans under §423 produce ordinary-income recognition on the 15 percent purchase discount plus capital-gain treatment on the appreciation between purchase and sale. Disqualifying dispositions before the qualifying holding period (two years from grant, one from purchase) recharacterize the gain as ordinary — multiplying the California 13.3 percent state tax on top.
4. Oracle §409A deferred-comp timing
Oracle's nonqualified deferred-compensation plans require strict distribution-timing election under §409A. Acceleration, modification outside the §409A(a)(4) rules, or failure to follow the 6-month delay for specified employees triggers a 20 percent additional tax plus interest under §409A(a)(1)(B). FICA timing under §3121(v)(2) is a separate issue.
5. Unreported FBAR exposure
Redwood City residents who emigrated from India, China, or the Pacific and retained ICICI / HDFC / SBI / Bank of China / ICBC / CCB / ANZ / BSP accounts past the $10,000 threshold without filing FinCEN Form 114 face $10,000 per-account-per-year non-willful penalties under 31 USC §5321 and the greater-of-$100,000-or-50-percent willful penalty on actual non-disclosure. Streamlined Filing Compliance Procedures resolve most cases.
6. FTB residency audit after Peninsula exit
Tech workers relocating from Redwood City to Austin, Reno, Boise, Coeur d'Alene, or Las Vegas often retain a Redwood Shores condo, Emerald Hills home, or Farm Hill property — all factors the FTB weighs to assert continuing California domicile under R&TC §17014. Deferred RSU vests and ESPP purchases post-exit can still be California-source.
7. Quarterly-estimate shortfall (1099 contractors)
Peninsula 1099 contract scientists, contract software engineers, marketing consultants, Stanford Health Care contracted physicians, Sequoia Hospital anesthesia and radiology group members, and Redwood City independent contractors underestimate quarterly Form 1040-ES and FTB 540-ES payments. SE tax under IRC §1401 plus federal and California income tax stack on net Schedule C, and a single year of underestimation rolls into multi-year balance once interest and §6654 penalty compound.
8. CDTFA sales-tax exposure (downtown retail)
Downtown Broadway and Middlefield restaurants, Sequoia Station retail, Redwood Shores office-park ancillary retail, and Stanford Shopping Center proximity retailers carry CDTFA sales-tax exposure when collected sales tax is not remitted. Personal dual-determinations under R&TC §6829 reach corporate officers and LLC members. Audit-period assessments can stretch back three to eight years.
9. ERC clawback exposure
Employee Retention Credit claims filed by promoter mills for Redwood City downtown restaurants, Sequoia Station retail, Redwood Shores small-business tenants, and Peninsula contract-research startups are being clawed back through CP207 and CP207L letters under the IRS Voluntary Disclosure Program and follow-on audits.
Who is on the hook: eight Redwood City liability scenarios
Joint filers (community-property state)
California is a community-property state under Cal. Fam. Code §760. Joint federal returns create joint-and-several liability under IRC §6013(d)(3). One Redwood City spouse can be pursued for the entire balance — even post-divorce — subject to Innocent Spouse Relief under IRC §6015 and R&TC §18533.
Divorce and tax allocation at San Mateo County Superior Court
The San Mateo County Superior Court Hall of Justice at 400 County Center handles Peninsula family-law matters, including the Family Law and Probate divisions. Allocation of joint federal liability, Oracle and EA RSU treatment as community property, Box and Equinix equity holdings, and stock-option division under Marriage of Hug all bear on the tax case. We coordinate with family-law counsel.
Responsible persons for payroll trust funds
TFRP under IRC §6672 reaches anyone with check-signing authority who willfully failed to pay over withheld taxes. IRC §7202 criminal exposure attaches to willful failure to collect or pay over — downtown Broadway and Middlefield restaurant operators, Sequoia Station inline-retail franchisees, Redwood Shores office-park tenant principals, and Peninsula contract-research startup officers all carry this risk. EDD's state TFRP analog is at UIC §1735.
CDTFA dual-determinations
CDTFA can issue personal dual-determinations against corporate officers, directors, and LLC members for unremitted sales tax under Cal. Rev. & Tax. Code §6829. Common with downtown Broadway and Middlefield, Sequoia Station, and Redwood Shores retail and restaurant groups.
FTB suspended-entity exposure
A Redwood City LLC suspended by FTB under R&TC §23301 loses its right to contract or defend in California courts. Officers signing on behalf may incur personal exposure. Common with single-member service LLCs and Peninsula contract-research startups that miss the $800 minimum franchise tax during downcycles. Revive via Form 3557 once compliance is current.
Transferee liability (Prop 19, family transfers)
IRC §6901 reaches transferees where the transfer rendered the transferor insolvent and tax debt remains. Common with Prop 19 parent-child transfers of Peninsula real estate since the February 2021 effective date. The post-2021 limit on the parent-child exclusion to primary residences pulled most second-home, rental, and investment-property transfers in Redwood Shores, Emerald Hills, and Farm Hill into reassessment at the San Mateo County Assessor.
Successor business liability
Asset purchases continuing a seller's Redwood City operation can carry CDTFA successor liability under R&TC §6811-6814 and EDD successor liability under UIC §1731. Buyers protect with CDTFA clearance letters before close — especially on Broadway restaurant and retail acquisitions, Sequoia Station inline-store transfers, and Redwood Shores office-park asset deals.
Estate and decedent returns
California has no state estate tax, but federal estate-tax planning under §2010 (unified credit), the §6166 estate-tax installment plan, the QTIP election under §2056(b)(7), and the stepped-up basis at death under §1014 are the central planning levers for Redwood City estates with appreciated Redwood Shores, Emerald Hills, Farm Hill, or Mount Carmel real property. The decedent's final 1040, the estate's 1041, and personal liability under 31 USC §3713(b) for premature distributions all attach to the executor.
What resolution can look like in Redwood City
Debt reduced
An accepted federal OIC settles the IRS liability for less than the full amount. A parallel FTB §19443 compromise can settle the California side. Partial Pay IAs cap recovery at what you can pay through the federal CSED or the FTB 20-year statute. Currently Not Collectible status freezes federal collection during tech-sector downturns, gaming-industry layoffs, post-divorce recovery periods, and family-bereavement events.
Penalties abated
Federal First-Time Penalty Abatement removes failure-to-file and failure-to-pay penalties for a clean compliance year. Reasonable-cause requests address 2017-2019 SF Bay Area PG&E PSPS events, 2020 SCU and CZU Lightning Complex smoke closures, COVID-era Peninsula office shutdowns, and serious illness. FTB waivers under §19131 and §19132 follow parallel principles. FBAR penalty mitigation through the Streamlined procedures runs separately.
Liens and levies released
A federal NFTL recorded with the San Mateo County Clerk-Recorder withdraws once a streamlined IA is in place under Fresh Start. FTB State Tax Liens release on payment, compromise, or release-for-cause. Wage and bank levies stop when the matter moves to CNC, IA, or OIC processing.
Outcomes vary. Past results do not guarantee future outcomes. Each tax case is unique.
Settlement ranges from the firm's case files
The following ranges come from Victory Tax Lawyers cases over the past several years and contribute to the firm's $100M+ aggregate tax-relief figure. Names and identifying facts are removed for confidentiality.
| Matter type | Original liability | Resolution | Approximate result |
|---|---|---|---|
| Installment Agreement | $138,296 | IRC §6159 streamlined IA | $25/month accepted |
| Partial Pay IA | $126,489 | IRC §6159 PPIA through CSED | $50/month accepted |
| Installment Agreement | $128,206 | IRC §6159 streamlined IA | $25/month accepted |
| Partial Pay IA | $116,451 | IRC §6159 PPIA through CSED | $50/month accepted |
| Installment Agreement | $152,296 | IRC §6159 streamlined IA | $25/month accepted |
Past results do not guarantee future outcomes. Each tax case is unique and turns on facts, asset position, monthly disposable income, IRS Allowable Living Expense tables, FTB equivalent standards, and the discretion of the assigned Revenue Officer, Settlement Officer, or FTB compromise reviewer. Acceptance rates for federal Offer in Compromise vary widely — the IRS reported a nationwide acceptance rate of roughly 30 to 40 percent in recent years.
Why work with a California-licensed firm on a Redwood City tax matter
A Redwood City tax matter rarely sits in one forum. A federal RSU underwithholding bill at Oracle, EA, Box, or Equinix triggers a parallel California assessment within four years through the federal-state information-exchange agreement. An ISO exercise at a pre-public Peninsula startup creates a federal AMT preference under §56(b)(3) and a California §17062 conformity question on the state side. An Oracle §409A deferred-comp distribution misstep produces the 20 percent additional tax federally plus FTB conformity exposure. An ICICI, Bank of China, or ANZ FBAR exposure crosses IRS Large Business & International FBAR examination, IRS Criminal Investigation review under 31 USC §5322, FinCEN administrative enforcement, and FTB residency factors in the same engagement. A downtown Broadway restaurant or Redwood Shores office-park tenant carries CDTFA sales tax, EDD payroll, FTB income, and City of Redwood City business-license matters at once. A San Mateo County government employee carries CalPERS, §457(b), and §401(k) considerations next to W-2 mainline taxation. A Stanford post-doc carries §117(a)/(c) scholarship sourcing plus J-1 / H-1B / O-1 treaty residency questions. A Redwood Shores or Emerald Hills Prop 8 appeal sits at 400 / 555 County Center while the parallel FTB residency audit runs at 121 Spear Street. A Redwood City-to-Austin or Redwood City-to-Reno exit puts Bragg, Bindley, Corbett, Reg. §17951-5(b), and deferred-RSU sourcing on the same audit file. These matters do not stay in their lanes.
Victory Tax Lawyers is admitted in California, headquartered in Los Angeles, and built around this overlap. Parham Khorsandi (Cal Bar #266658) and Amir Boroumand (Cal Bar #269570) appear directly before the FTB, CDTFA, EDD, and OTA, and on the federal side before the IRS and the U.S. Tax Court. The same attorneys handle the whole engagement — no Form 2848 workaround, no referral chain through out-of-state counsel.
California Rule of Professional Conduct 7.1 governs lawyer advertising in the state. No superlatives without verifiable substantiation, no specific dollar guarantees, no testimonials without disclaimers. The firm operates under those rules natively. This page does not promise outcomes, does not promote dollar averages, and does not list testimonials without context.
If your case is purely federal — an IRS audit, a Tax Court petition with San Francisco place of trial, an Offer in Compromise, an FBAR Streamlined Filing — we handle it under Tax Court bar admission, Circular 230, and a Form 2848 Power of Attorney. The California-licensed difference shows up when the state side appears, which it usually does in Redwood City.
The seven steps of a VTL tax-resolution engagement
Free consultation
A 30-minute call with an attorney to outline the facts, the IRS or FTB notices received, and realistic resolution options.
Engagement letter
A written attorney-client agreement defines scope, fee, and authority. California-bar privilege and federal common-law privilege both attach.
Federal & state PoA
Form 2848 filed with the IRS, FTB Form 3520, CDTFA Form 392, or EDD DE 48 filed with the relevant California agency. Notices route to counsel.
Transcript investigation
IRS Account Transcripts, Wage-and-Income Transcripts, and Record of Account pulled across all open years. FTB MyFTB, CDTFA, and EDD records pulled. Federal CSED and California 20-year statute dates verified.
Strategy memo
A written analysis recommending federal OIC, IA, CNC, audit response, CDP, Streamlined FBAR Filing, or Tax Court petition with the FTB, CDTFA, or EDD parallel strategy where applicable.
Resolution filed
Federal Forms 656, 433-A, 9423, 12153, FinCEN Form 114, Form 8938, or Tax Court Petition. State FTB Form 4905, CDTFA offer, or EDD compromise. Negotiations with Revenue Officers, Settlement Officers, Appeals Officers, FTB analysts, CDTFA supervisors, and OTA hearings handled directly.
Compliance close-out
Post-resolution monitoring: quarterly estimates, return filings, FBAR annual filings going forward, and protection against IA default. The case is done when the new pattern is stable, not when the offer is accepted.
Collection statute warning — the California 20-year tail
Under IRC §6502(a), the IRS has ten years from the date of assessment to collect. After the federal Collection Statute Expiration Date, the debt becomes uncollectible by operation of law. Tolling events extend the federal CSED: a pending OIC (extends by OIC pendency plus 30 days), bankruptcy (extends by stay plus six months), Collection Due Process hearings, Innocent Spouse claims, and continuous absence from the United States for six months or more.
The California side is the opposite of forgiving. Under Cal. Rev. & Tax. Code §19255, the FTB has 20 years from the latest of assessment, due date, or final return filing to collect — double the federal CSED. CDTFA collection runs 10 years under §6711 with similar tolling. EDD operates under its own collection window in the Unemployment Insurance Code.
A federal Redwood City balance assessed in 2016 may approach CSED expiration in 2026, while the FTB equivalent continues to be collectible until 2036. Submitting a federal OIC restarts the federal clock. Sometimes a Partial Pay IA that runs out the federal statute is the better federal play, paired with a separate FTB compromise to address the longer state tail. The two strategies are decided together.
Redwood City venue: federal and state tax forums
A Redwood City tax matter may proceed in any of several federal or state forums depending on the type of liability. Below are the offices, courthouses, and agencies serving the city. Because Redwood City is the seat of San Mateo County, multiple county-level forums sit within walking distance of one another at 400 County Center and 555 County Center.
U.S. Tax Court — San Francisco trial sessions
The United States Tax Court holds Northern California trial sessions at the Phillip Burton Federal Building and U.S. Courthouse, 450 Golden Gate Avenue, San Francisco CA 94102. A Redwood City petitioner designates "San Francisco, California" as the place of trial on the petition under Tax Court Rule 140. Sacramento at 501 I Street is an alternative where docket timing favors it.
IRS San Mateo Taxpayer Assistance Center
The IRS operates the closest TAC for Redwood City at 977 South Claremont Street, San Mateo CA 94402 — roughly 8 miles north via El Camino Real or US-101. Alternative venues are the San Francisco TAC at 450 Golden Gate Avenue inside the Phillip Burton Federal Building and the Oakland TAC at 1301 Clay Street inside the Ronald V. Dellums Federal Building. Appointments through apps.irs.gov/app/office-locator or 844-545-5640. For most resolution work, in-person visits are not required — we represent clients by Form 2848 PoA and route notices directly to counsel.
U.S. District Court — NDCA, San Francisco / San Jose
Federal refund suits and criminal-tax cases proceed in the U.S. District Court for the Northern District of California. The San Francisco Division sits at the Phillip Burton Federal Building, 450 Golden Gate Avenue. The San Jose Division sits at the Robert F. Peckham Federal Building, 280 South First Street. The Oakland Division sits at the Ronald V. Dellums Federal Building, 1301 Clay Street. Peninsula cases route to SF or San Jose based on case-assignment. Appellate review goes to the Ninth Circuit at 95 Seventh Street in San Francisco.
FTB San Francisco Field Office (121 Spear St)
The California Franchise Tax Board San Francisco Field Office is at 121 Spear Street, Suite 400 — the home FTB office for Peninsula residents and businesses: residency audits under R&TC §17014, Notice of Proposed Assessment protests, FTB Settlement Bureau review under §19443, and walk-in services for individual taxpayers. The FTB San Jose Field Office at 96 N. Third Street, Suite 600 is the South Bay alternative.
CDTFA San Francisco District Office
The California Department of Tax and Fee Administration San Francisco District Office at 121 Spear Street serves San Mateo County including Redwood City. Petitions for Redetermination, appeals conferences, and offer reviews route through this office for sales-tax, use-tax, and fuel-tax work. Verify current address through cdtfa.ca.gov/office-locations.htm before any walk-in visit.
San Mateo County Superior Court — Hall of Justice
The San Mateo County Superior Court Hall of Justice at 400 County Center, Redwood City CA 94063 is the primary county venue for civil, criminal, family, probate, and small-claims matters. R&TC §19382 / §19385 refund suits, divorce-tax allocation, probate-tax matters, and county business-tax disputes proceed here.
San Mateo County Assessor & AAB
The San Mateo County Assessor at 555 County Center, Redwood City CA 94063 administers Prop 13 base-year values, Prop 19 parent-child transfers, supplemental assessments, and the property roll across Redwood City. The Assessment Appeals Board at the Clerk of the Board, 400 County Center, hears reassessment petitions under R&TC §1603-1611. San Mateo County uses the September 15 filing deadline for the regular roll.
San Mateo County Treasurer-Tax Collector
The San Mateo County Treasurer-Tax Collector at 555 County Center, Redwood City handles property-tax billing and collection across the county. Redwood City property-tax delinquencies on Redwood Shores, Emerald Hills, Farm Hill, Mount Carmel, Roosevelt, and downtown parcels proceed through this office.
California Office of Tax Appeals
The California Office of Tax Appeals is headquartered in Sacramento at 400 R Street with a Southern California hearing room at 355 South Grand Avenue, Los Angeles and a San Francisco hearing room. Video appearance is the practical option for most Redwood City matters. OTA petitions follow a 30-day window from an FTB or CDTFA Notice of Action under R&TC §19045 / §19324.
California Court of Appeal, First District
Appeals from San Mateo County Superior Court go to the California Court of Appeal, First Appellate District, at 350 McAllister Street, San Francisco CA 94102 — the appellate division serving the Bay Area counties through Divisions One through Five.
City of Redwood City — business license & TOT
The City of Redwood City administers the business-license tax under the Redwood City Municipal Code from City Hall at 1017 Middlefield Road, Redwood City CA 94063, with Public Works at 1400 Broadway. Redwood City imposes a transient occupancy tax on hotels and short-term lodging. Downtown Broadway and Middlefield retailers, Sequoia Station operators, Redwood Shores ancillary-retail tenants, home-based contractors, and short-term rental owners all need current business licenses on file with the Finance Department.
San Mateo County Clerk-Recorder
The San Mateo County Assessor-County Clerk-Recorder at 555 County Center, Redwood City records federal Notices of Federal Tax Lien under IRC §6323, FTB State Tax Liens under Cal. Gov. Code §7171, deeds of trust, satisfaction-of-mortgage filings, and quitclaim transfers across the county. Lien release, certificate of discharge, subordination, and withdrawal filings on Redwood City parcels route through this office.
Request a free consultation with a Redwood City tax attorney
A 30-minute call with an attorney costs nothing. Bring your most recent IRS notice, last filed federal and California returns, any FTB or CDTFA or EDD correspondence, and — if you work at Oracle, Electronic Arts, Box, Equinix, Informatica, Stripe, Roblox, Stanford Health Care, Sequoia Hospital, or Kaiser Permanente Redwood City; if you work for San Mateo County government at 400 / 555 County Center; if you teach in Sequoia Union High School District; if you hold accounts at ICICI / HDFC / SBI / Bank of China / ICBC / CCB / ANZ / BSP; if you own Redwood Shores, Emerald Hills, Farm Hill, or Mount Carmel property; or if you commute to Stanford or San Francisco — your most recent W-2, 1099, K-1, Schedule E, Schedule C, RSU and option statements, ESPP confirmations, §409A election forms, and foreign-account statements. We will tell you which resolution options fit your facts on both sides before you sign anything.
Principal office: 1100 S. Robertson Boulevard, Los Angeles, CA 90035. Statewide California service including Redwood City and all of San Mateo County.
Frequently asked questions — Redwood City
Author & reviewer
Written by Amir Boroumand, Esq.
Managing Attorney · California Bar #269570 · Admitted to the United States Tax Court
Amir Boroumand is a managing attorney of Victory Tax Lawyers, LLP, headquartered at 1100 S. Robertson Boulevard in Los Angeles. His practice covers federal and California tax controversy across the state, including Redwood City matters: Oracle RSU, ISO, AMT, ESPP §423, §409A nonqualified deferred compensation, and §415 high-three retired-pay representation for the 500 Oracle Parkway executive and senior-employee workforce; Electronic Arts gaming-industry RSU, ISO, and ESPP work for the 209 Redwood Shores Parkway team plus §174 R&E and §41 research-credit coordination; Box and Equinix equity-comp work; Stripe and Roblox proximity engagements; §1202 QSBS planning for early-stage Peninsula founders; FBAR, Form 8938, Form 8621 PFIC, and Streamlined Filing Compliance Procedure work for the Redwood City Indian-American (ICICI, HDFC, State Bank of India, Axis, Kotak Mahindra), Chinese-American (Bank of China, ICBC, China Construction Bank, Agricultural Bank, China Merchants), and Pacific Islander (ANZ, Bank of South Pacific, Westpac, BSP) communities; Prop 8 decline-in-value appeals at the San Mateo County Assessment Appeals Board at 400 County Center; Prop 13 base-year and Prop 19 parent-child transfer analysis at the San Mateo County Assessor at 555 County Center; FTB residency audits following moves to Austin, Reno, Boise, and Coeur d'Alene; San Mateo County government employee CalPERS plus §457(b) plus §401(k) coordination; Stanford University faculty and post-doc §117(a)/(c) and §403(b) work; Caltrain Peninsula transit-fringe and cross-county wage-sourcing matters; Sequoia Hospital, Kaiser Permanente Redwood City, and Stanford Health Care 1099 contracted-physician returns; City of Redwood City business-license and transient-occupancy tax matters; and U.S. Tax Court petitions designated to the San Francisco trial city.
Last Reviewed:
Reviewed by Parham Khorsandi, Esq.
Managing Attorney · California Bar #266658 · Pepperdine Caruso School of Law, JD 2009
Reviewed for accuracy of California statutory citations (R&TC, UIC, Government Code), federal Internal Revenue Code citations, named California and federal entities (FTB San Francisco at 121 Spear Street, CDTFA San Francisco, OTA, San Mateo County AAB at 400 County Center, San Mateo County Assessor at 555 County Center, IRS San Mateo TAC at 977 South Claremont Street, NDCA San Francisco Division, U.S. Tax Court San Francisco, City of Redwood City at 1017 Middlefield Road, San Mateo County Superior Court Hall of Justice at 400 County Center), FBAR and Form 8938 framework citations (31 USC §5314, IRC §6038D, IRC §1297, 31 CFR §1010.350), Oracle §409A and §415 nonqualified deferred compensation citations, Stanford §117 and §403(b) citations, and consistency with California Rule of Professional Conduct 7.1 on lawyer advertising. Dual-attorney review is the firm's standard for geographic-practice content.
Attorney Advertising. Victory Tax Lawyers, LLP is a California-licensed law firm with its principal office at 1100 S. Robertson Boulevard, Los Angeles, CA 90035. Information on this page is general in nature, may not reflect the most recent legal developments, and does not create an attorney-client relationship. This page is not legal advice. Federal and California tax outcomes depend on individual facts and the discretion of the Internal Revenue Service, the Franchise Tax Board, the California Department of Tax and Fee Administration, the Employment Development Department, FinCEN, or the relevant tribunal. Past results do not guarantee future outcomes; each tax matter is unique.
IRS Circular 230 Disclosure. To ensure compliance with requirements imposed by the IRS, any U.S. federal tax advice contained on this page is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing, or recommending to another party any transaction or matter addressed herein.
California-specific note. VTL attorneys are members of the State Bar of California in active standing. California state-tax matters (FTB, CDTFA, EDD, OTA) and federal IRS / U.S. Tax Court matters are handled directly by the firm. Oracle, Electronic Arts, Box, and Equinix RSU, ISO, ESPP, AMT, and §409A planning, §1202 QSBS work, FBAR and Form 8938 cross-border compliance for Indian-American, Chinese-American, and Pacific Islander clients, Prop 8 decline-in-value AAB appeals, FTB residency audits, San Mateo County government employee CalPERS / §457(b) coordination, and Stanford University faculty and post-doc §117 work each require accurate underlying documentation. Consult a licensed attorney about your specific situation before acting on any content on this page. The State Bar of California Rule of Professional Conduct 7.1 requires that lawyer communications not be false or misleading; this page strives to comply and does not promise specific outcomes.
Related VTL practice areas
Offer in Compromise
IRC §7122 settlement
Installment Agreement
IRC §6159 payment plan
Tax Lien
IRC §6321 release
Tax Levy
IRC §6331 release
Audit Representation
IRS exam defense
Penalty Abatement
First-Time and reasonable cause
Back Taxes
Unfiled returns and balances
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