Tax Attorney in Seattle, WA

Often yes — on income sourced to California even after the move. Under Cal. Rev. & Tax. Code §17041 and FTB Publication 1031's nine-factor residency test, equity compensation that vested while you rendered services in California is California-source income on sale, even years after you relocate. Severance and deferred comp tied to California services follow the same rule. The FTB issues residency audits on a four-to-six-year lookback. 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. We see this pattern weekly with Amazon, Microsoft, T-Mobile, and Expedia transplants who left Bay Area roles after 2020.

No personal income tax in the traditional sense. Washington is one of seven states without a state PIT. But that does not mean Washington tax is simple. Three structural pieces matter: the Business & Occupation tax under RCW 82.04 (a gross-receipts tax on every business activity in the state — no deduction for COGS or expenses); the new 7% Capital Gains Tax under RCW 82.87 on long-term gains above the indexed threshold ($262,000 for 2026), upheld in Quinn v. State (2023); and the WA Estate Tax under RCW 83.100 with a $2.193M exemption. Sales-and-use tax runs 6.5% state plus Seattle local rates that total 10.25% combined — one of the highest combined rates in the country.

The WA Capital Gains Tax is a 7% state excise tax on long-term capital gains above a $262,000 annual threshold (2026 indexed amount) under RCW 82.87. It was enacted in 2021, took effect for the 2022 tax year, and was upheld as a constitutional excise tax (not an income tax) by the Washington Supreme Court in Quinn v. State, 196 Wn.2d 410 (2023). Real estate is excluded under RCW 82.87.050(2). Sales of qualified small-business stock under IRC §1202 receive a separate carve-out. RSU vest gains that fall into long-term holding can hit the threshold quickly for Amazon and Microsoft employees; we coordinate the federal §1(h) long-term rate with the WA 7% layer on the same gain and advise on the timing of large lots.

Fundamentally. The Business & Occupation tax under RCW 82.04 is a gross-receipts tax: it applies to total business revenue with no deduction for cost of goods sold, no deduction for business expenses, no deduction for compensation paid, and no deduction for depreciation. Federal income tax under Subtitle A of the Internal Revenue Code is a net-income tax. The B&O rate depends on classification: 0.471% for Retailing, 1.5% for Service & Other Activities, 1.75% for Royalties / Services (for higher-receipt businesses), and various other classifications by industry. Misclassification is the most common B&O audit issue — a Seattle consultancy reported as Retailing instead of Service & Other faces a multi-year DOR reassessment. The economic burden also differs — a startup with zero net profit can still owe substantial B&O because the tax is on gross.

The U.S. Tax Court holds Seattle trial sessions at the Tom Lantos U.S. Courthouse at 700 Stewart Street, Seattle WA 98101. A petitioner designates Seattle as the preferred place of trial on the petition under Tax Court Rule 140. Sessions are scheduled on rotation rather than monthly. If the Seattle calendar is overcrowded, the case may also route to Portland or Anchorage depending on the judge's schedule. Small-tax-case procedure under IRC §7463 is available for deficiencies of $50,000 or less per year.

An incentive stock option exercise creates an Alternative Minimum Tax preference equal to the spread between exercise price and fair market value on exercise date, under IRC §56(b)(3) and §55, subject to ISO qualification rules at IRC §422. If you exercise-and-hold past the calendar year, you owe AMT on that phantom spread even if you never sell, and even if the stock subsequently drops below the exercise price. The AMT credit under IRC §53 lets you recover the prepayment over future years when regular tax exceeds tentative minimum tax — but the cash-flow squeeze in the exercise year is real. Disqualifying-disposition planning (selling within the same year) avoids AMT but converts the spread to ordinary income. IRS §6662(b)(1) accuracy-related penalty exposure applies when AMT is computed incorrectly on Form 6251.

Under RCW 82.32.050, the Washington Department of Revenue generally has four years from the close of the tax year to assess a deficiency on B&O, sales-and-use, and other excise taxes. The period extends where the return was not filed, where fraud is found, or where the taxpayer signs a written waiver. The federal IRS Collection Statute Expiration Date (10 years from assessment under IRC §6502) runs independently. The new WA Capital Gains Tax under RCW 82.87 has its own statute. For Seattle transplants from California, the 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.

Yes. A levy under IRC §6331 reaches property and rights to property held by or for the taxpayer, including brokerage accounts. Once the broker (Fidelity, E-Trade, Charles Schwab, Morgan Stanley, Solium for Amazon and Microsoft plans) receives a levy, it segregates the account and holds funds for 21 days under IRC §6332(c) before remittance. Vested-but-unsold shares are fully reachable. Unvested RSUs sit in a narrower category — the IRS levy power on contingent property is more limited — but vested cash-settled positions and vested-but-unsold shares move into liquid status. Acting in the 21-day window matters: a properly-filed CDP request or accepted CNC suspends the levy before the broker remits and avoids forced liquidation at an unfavorable price on a concentrated single-stock position.

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, even a controller in certain fact patterns. For Seattle SaaS startups, this often catches multiple people because cap-table authority and check-signing authority overlap. On the state side, RCW 82.32.145 reaches officers and members for collected-but-unremitted retail sales tax, plus parallel WA Employment Security Department exposure for unemployment-insurance contributions.

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. Seattle engineers traveling to Asia for Amazon or Microsoft operations work, founders raising capital overseas, and remote workers spending extended time abroad face real revocation exposure. Decertification typically processes within 30 days once a qualifying resolution is in place.

If the aggregate balance across all your foreign accounts exceeded $10,000 at any point during the calendar year, yes. FinCEN Form 114 (FBAR) is required under 31 USC §5314 and is filed separately from the federal income-tax return on the FinCEN BSA e-file system. IRS Form 8938 is a separate statement filed with Form 1040 at higher thresholds. For Seattle filers with accounts in China, Hong Kong, Vietnam, the Philippines, Japan, Korea, or India, both forms may apply. Streamlined Filing Compliance Procedures resolve good-faith past nondisclosure without the willful FBAR penalty — the penalty for willful nondisclosure can reach 50% of the account balance per year. The Streamlined program is currently open and is the right path when there is no badge of fraud.

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 Seattle transplant runs higher because it involves two agencies and two statutes. VTL provides a written fee quote after the free consultation. California 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.

For administrative work at the Washington Department of Revenue — responding to a Notice of Determination, filing a Petition for Correction, working with the DOR Appeals Division on a B&O or sales-tax reassessment — representation runs through a Washington DOR power of attorney. The DOR accepts representation by attorneys, CPAs, and other authorized representatives. For formal appeal to the Washington Board of Tax Appeals under RCW Chapter 82.03, the BTA permits representation by attorneys, CPAs, and individuals with proper authorization. For judicial review in King County Superior Court, an attorney admitted in Washington is required — VTL refers to local Washington counsel for that stage and stays engaged on the federal side. Many WA tax disputes resolve at the DOR Appeals or BTA stage without ever reaching state court.

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.