Tax Attorney in Rhode Island

Yes. Rhode Island runs a graduated personal income tax with three brackets: 3.75%, 4.75%, and a top rate of 5.99% for 2026. The state also imposes a 7% flat corporate income tax under R.I. Gen. Laws Title 44, Chapter 11. Filing is on the RI-1040 (or RI-1040NR for non-residents). Federal income tax (Form 1040 with the IRS) applies separately and is what most of our resolution work focuses on.

Providence is a listed U.S. Tax Court place of trial. Sessions are calendared in Providence when the caseload supports it; otherwise, Rhode Island petitioners often select Boston as the practical alternative under Tax Court Rule 140. Boston has a permanent Tax Court courtroom and a heavy session schedule, and is roughly an hour from Providence by car or commuter rail.

Under R.I. Gen. Laws §44-30-82, the Division of Taxation generally has three years from the date a return was filed to assess additional personal income tax. The period extends to six years where there is a substantial understatement of more than 25% of gross income, and there is no time limit for fraudulent returns or unfiled returns. The federal IRS Collection Statute Expiration Date (10 years from assessment under IRC §6502) runs independently from the state SOL.

Yes. The IRS examines federal income tax, federal employment tax, and federal excise tax. The Rhode Island Division of Taxation examines state personal income tax, corporate income tax, sales-and-use tax, withholding tax, and estate tax. A Rhode Island business can simultaneously face an IRS payroll audit (Form 941 issues) and a Division of Taxation sales-tax audit. The two agencies share information through a federal-state exchange agreement, and an IRS Revenue Agent Report (RAR) adjustment commonly triggers a Rhode Island follow-up assessment.

Yes. The Rhode Island Division of Taxation operates an Offer in Compromise program under R.I. Gen. Laws Title 44 that mirrors the federal IRC §7122 structure. The state evaluates doubt as to collectibility and doubt as to liability using a financial-disclosure form similar to federal Form 433-A. State acceptances are typically smaller dollar matters than the federal IRS program handles, but the framework is parallel. We coordinate state and federal OICs together when both balances exist.

The federal estate-tax exemption for 2026 sits near $13.6M per decedent. Rhode Island's state estate-tax exemption sits near $1.7M for 2026 deaths — one of the lowest in the country — with rates progressing from roughly 0.8% up to 16% on amounts above the exemption. The result: many Rhode Island estates that owe no federal tax still owe Rhode Island estate tax. Executors file federal Form 706 (when required) and the Rhode Island RI-100 separately. We see this regularly with East Greenwich, Barrington, and Newport homes combined with retirement accounts and life insurance.

Your CSED is calculated from the date of assessment, which appears on your IRS Account Transcript as Transaction Code 150 (return filed) or Transaction Code 290 (additional assessment). Add ten years, then add the days for any tolling events: pending OICs, CDP hearings, bankruptcy stays, and so on. The IRS publishes the CSED date internally on its CC ACTRA transcript; we pull this for clients as part of every engagement. A debt assessed in 2016 may be approaching expiration in 2026, and aggressive enforcement near the CSED is common.

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, not the employer's share. 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. On the state side, R.I. Gen. Laws §44-19-35 imposes parallel personal liability on officers responsible for unremitted sales tax.

Yes. You file a Massachusetts non-resident return (Form 1-NR/PY) reporting the wages earned in Massachusetts, then file your Rhode Island resident return (RI-1040) reporting worldwide income and claim a credit for taxes paid to Massachusetts under R.I. Gen. Laws §44-30-18. The credit is limited to the lower of the actual MA tax paid or the RI tax that would have applied to the same income. Payroll-system misallocation during remote-work years has driven a wave of CP2000 federal notices and dual-state state assessments — an audit-ready return reconstruction is often required.

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. For Brown University researchers, Lifespan and Care New England physicians, and Newport-based hospitality professionals with international travel, decertification is often urgent and can be processed in 30 days or less.

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 complexity. 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, etc.). 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. An attorney handling your tax case retains the broader privilege that survives criminal investigation.

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 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 bears the burden of proof on most issues, presents evidence and witness testimony, and the Court issues a written opinion typically within several months of trial. Small-tax-case procedure under IRC §7463 applies to deficiencies of $50,000 or less per year and uses a simplified evidentiary standard.

Yes, generally. IRC §6331(k)(1) suspends levy action while an offer is pending and for 30 days after a rejection, and 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. CSED is also tolled during the pendency. A poorly-prepared OIC that gets returned (not rejected) does not provide the same protection — processability matters.

For an administrative hearing at the Division of Taxation, a taxpayer may represent themselves or be represented by an attorney, a CPA, or another authorized representative. For appeals to the Rhode Island District Court and the Rhode Island Supreme Court, an attorney admitted in Rhode Island is required for formal court appearance. VTL handles the federal side of overlapping matters and coordinates with Rhode Island counsel where state-court litigation is necessary. Many Division of Taxation disputes resolve at the administrative hearing stage without ever reaching District Court.