Tax Attorney in Reno, NV

Often yes — on income sourced to California even after the move. Under Cal. Rev. & Tax. Code §17041 and FTB Publication 1031, equity compensation that vested while you rendered services in California is California-source income on sale, even years after you relocate to Washoe County. Severance and deferred comp tied to California services follow the same rule. The FTB issues residency audits on a four-to-six-year lookback and applies a nine-factor test to evaluate whether the move was bona fide or whether you retained a California domicile. The move itself is fully legal — what catches people is filing as a nonresident for the year of relocation without sourcing the pre-move California-earned items properly. The Reno-Tahoe corridor receives a heavy stream of Bay Area, Sacramento, and Los Angeles transplants, and we handle this pattern frequently. The FTB has a 20-year collection horizon under Cal. Gov. Code §7172 and Cal. Rev. & Tax. Code §19255 — twice the federal CSED.

RSUs (restricted stock units) are taxed as ordinary W-2 wages at vesting under IRC §83. The employer withholds at the supplemental rate (22% federal under $1 million in supplemental wages per year, 37% over the threshold) plus Medicare and Additional Medicare under IRC §3101. The shortfall when your marginal rate exceeds 22% creates a year-end balance and IRC §6654 underpayment-penalty exposure unless quarterly estimates are paid. ISOs (incentive stock options) get different treatment: no ordinary-income tax at exercise, but the spread between exercise price and fair market value is an AMT preference item under IRC §56(b)(3) and IRC §422. AMT on a large ISO exercise can be a six-figure tax bill in a year with no cash sale. An §83(b) election within 30 days of a restricted-stock grant (not RSUs — RSUs do not qualify) can lock in low-basis ordinary income at grant rather than vesting. For Gigafactory employees who moved from California before vesting, the FTB may still claim California source on the pre-move portion under Publication 1031.

No. Nevada is among the most prominent no-personal-income-tax states — the Nevada Constitution prohibits a state income tax on individuals. Nevada also has no conventional state corporate income tax. The state instead imposes a Modified Business Tax under NRS Chapter 363B (1.378% on Nevada wages above the quarterly threshold), a Commerce Tax under NRS Chapter 363C (graduated 0.051% to 0.331% on Nevada-sourced gross revenue above $4 million, with rates varying by industry classification), and sales-and-use tax (6.85% state plus 1.415% Washoe County for an 8.265% combined rate in Reno). Federal income tax filed on Form 1040 with the IRS applies in full. This profile is what makes Reno and Incline Village attractive to ex-California residents, including many Tesla, Apple, Google, and Meta alumni.

The U.S. Tax Court holds Reno trial sessions at the Bruce R. Thompson Federal Building at 400 South Virginia Street, Reno NV 89501. A petitioner designates Reno as the preferred place of trial on the petition under Tax Court Rule 140. Sessions are scheduled on rotation rather than monthly. If the Reno calendar is overcrowded, the case may also route to Las Vegas depending on the judge's schedule. Small-tax-case procedure under IRC §7463 is available for deficiencies of $50,000 or less per year.

Three federal items recur on Incline Village and Crystal Bay STR audits. First, IRC §280A limits deductions when personal use exceeds the greater of 14 days or 10% of rental days — many Tahoe owners trip the personal-use clock with family ski weeks blocking. Second, if the average rental period is seven days or less, the activity is not "rental" for passive-loss purposes — it is a trade or business under Treas. Reg. §1.469-1T(e)(3), which means material-participation testing under IRC §469 controls whether losses are deductible. Third, depreciation classification — furniture, fixtures, and the 27.5-year residential schedule versus cost-segregation acceleration under IRC §168 — is frequently mishandled on the original return and reopened on audit. Layer on Washoe County STR licensing, the Tahoe Regional Planning Agency overlay, and the geographic patchwork of where short-term rentals are permitted at all. Incline Village's no-state-income-tax setup attracts billionaire and high-net-worth owners specifically because the NV side of Lake Tahoe is a recognized residency-and-asset-protection corridor; the federal §280A analysis still applies in full.

Slot and video-poker jackpots of $1,200 or more, keno winnings of $1,500 or more, poker tournament wins of $5,000 or more, and other gambling payouts at threshold amounts at the Atlantis, Peppermill, Eldorado, Silver Legacy, Circus Circus (Caesars), Grand Sierra Resort, or Bonanza trigger Form W-2G reporting from the casino to the IRS. Backup withholding of 24% applies under IRC §3402(q) where the payment exceeds the threshold and the player does not furnish a TIN. The full winnings are includible in gross income on Schedule 1. Gambling losses are deductible only against winnings and only if you itemize on Schedule A under IRC §165(d) — a session-based recordkeeping approach is required, and casual gamblers cannot offset losses against ordinary income. Professional gamblers report on Schedule C under Commissioner v. Groetzinger with the trade-or-business standard. The IRS will aggregate every W-2G the casinos report on you across the year; underreporting triggers an automated CP2000.

Nevada does not have a unified state SOL framework like California's R&TC. Sales-and-use tax assessments from the Nevada Department of Taxation generally operate on a three-year SOL from the original return due date, extended where returns are unfiled or fraud is established. Modified Business Tax and Commerce Tax SOL frameworks are set in NRS Chapters 363B and 363C respectively. A deficiency determination by the Department triggers a 30-day petition window to the Nevada State Board of Tax Appeals under NRS §360.245. The federal IRS CSED (10 years from assessment under IRC §6502) runs independently. For Reno-Tahoe transplants, the California FTB applies a four-year SOL on assessment (extended to six years for substantial omissions and unlimited for unfiled returns) under Cal. Rev. & Tax. Code §19057, plus the 20-year collection horizon under Cal. Gov. Code §7172.

Yes. A wage levy under IRC §6331 reaches wages, salary, and other compensation, including paychecks from Tesla, Panasonic, Switch, Amazon Sparks fulfillment, Dermody, UNR, and any Reno-area casino or hospitality employer. The levy is continuous — it remains in place until released, the debt is paid, or the IRS removes it. The exempt amount you keep is tied to your filing status and dependents under IRC §6334(d) and is set by Publication 1494. For a single filer with no dependents, the exempt amount can leave you with very little of a typical Gigafactory or casino paycheck. Tip income reported by the employer is part of wages and subject to the levy; cash tips paid directly by guests are technically not, but the IRS can reach those through bank levies or other collection tools. CDP requests, CNC status, an accepted IA, or an accepted OIC suspends the levy.

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 owners, head-of-finance, even a general manager in certain fact patterns. For Reno-area hospitality businesses with multiple investors or layered LLC structures, the TFRP often catches more than one person. On the state side, Nevada Modified Business Tax responsible-person exposure operates on similar principles, and unpaid Nevada sales-and-use tax collected in trust from customers creates an additional state-side personal-exposure question.

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. Reno-area Tesla engineers traveling to Berlin, Shanghai, or Grunheide on rotation, Panasonic Japanese-expatriate technicians, UNR faculty on international conferences, and Tahoe-side founders raising capital 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. A combined federal-plus-California FTB residency audit defense for a Reno-Tahoe transplant runs higher because it involves two agencies and two statutes. 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 risk that increases in Reno matters involving large cash transactions, casino currency-transaction reports under 31 USC §5331, or structured deposits.

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-level work at the Nevada Department of Taxation Reno office on Kietzke Lane, taxpayers may be represented by an attorney, a CPA, or another authorized representative under Department rules. VTL files the state-level Power of Attorney and handles the administrative matter remotely. For a Nevada State Board of Tax Appeals petition, the Board permits representation by counsel admitted in any U.S. jurisdiction in many fact patterns, though for judicial review in the Second Judicial District Court of Washoe County, a Nevada-admitted attorney is required (pro hac vice admission is available for out-of-state counsel under Nevada Supreme Court Rule 42). VTL handles the federal side of overlapping matters and coordinates with local Nevada counsel where state-court litigation is necessary. Many Department of Taxation disputes resolve at the administrative stage without ever reaching state court.