Atty. Jonathan E. Strouse

Mr. Strouse has represented thousands of taxpayers that cut across diverse boundaries including, but not limited to, trusts, estates, federally recognized Indian tribes and tribal members, municipal governments, foreign taxpayers, hedge funds, high-net-worth individuals, trustees of qualified ERISA plans including leveraged and non-leveraged ESOPs, accountants, not-for-profit and tax-exempt entities, TEFRA partnerships, individuals involved in Derivium transactions, and S and C corporations (publicly traded corporations as well as privately held). Mr. Strouse has represented a variety of taxpayers before the Internal Revenue Service on a wide variety of collection, examination, and appeal matters including, but not limited to, listed transactions and other tax avoidance matters, foreign tax issues, "wealth squad" examinations, "Midco" and section 6901 transactions, valuation issues, domestic and offshore voluntary disclosures including streamlined filings, FBAR issues, the trading safe harbor pursuant to Section 864(b), information reporting issues, penalty matters pursuant to Sections 6662 and 6707A, mediation proceedings pursuant to Rev. Proc. 2009-44, transfer tax issues, and various other corporate, partnership, individual, employment, and excise tax matters.