Trusted Counsel.
Strategic Advocacy.
Providing sophisticated tax solutions with integrity, insight, and a relentless commitment to results — for individuals and businesses alike.
Practice Areas
The Karam Firm provides sophisticated tax law counsel across the full spectrum of federal, state, and international tax matters — from proactive planning and transactional advice to aggressive dispute resolution and criminal defense.
-
Aggressive representation at every stage of a tax dispute.
When the IRS or a state taxing authority comes calling, you need counsel who knows the process from the inside. The Karam Firm provides skilled representation through every phase of a tax controversy — from the initial audit notice through administrative appeals, Tax Court, and federal district court litigation — working to resolve matters efficiently and on the most favorable terms possible.
Representative Services
IRS audit representation (correspondence, office, and field)
IRS Independent Office of Appeals
U.S. Tax Court litigation
Federal district court and Court of Federal Claims
Collection Due Process (CDP) hearings
Offers in Compromise and installment agreements
Penalty abatement and reasonable cause arguments
State tax audit defense and administrative appeals
Who We Serve
Individuals and businesses facing IRS or state tax audits, assessments, collection actions, or tax litigation who need experienced counsel to protect their rights and minimize exposure.
-
Authoritative written analysis to support your positions and manage risk.
A well-reasoned tax opinion from qualified counsel provides critical protection — establishing reasonable cause, reducing penalty exposure, and giving clients the confidence to proceed with complex transactions. The Karam Firm also assists clients in obtaining private letter rulings and other guidance directly from the IRS when certainty is essential.
Representative Services
Should-file and will-succeed opinion letters
More-likely-than-not and substantial authority opinions
Penalty protection opinions
Transaction-specific tax opinions
Private letter ruling requests
Technical advice memoranda
Closing agreement negotiations
Reliance opinions for tax planning strategies
Who We Serve
Businesses, investors, and individuals undertaking complex transactions or tax positions who need authoritative written analysis or formal IRS guidance to support their reporting.
-
Comprehensive tax counsel across all jurisdictions.
Tax obligations do not stop at state or national borders. The Karam Firm provides integrated federal, state, and international tax advice — helping clients understand their obligations, structure transactions efficiently, and stay compliant across every jurisdiction in which they operate or invest.
Representative Services
Federal income tax planning and compliance
Multi-state nexus analysis and compliance
International tax planning (inbound and outbound)
FBAR and FATCA compliance
Foreign account and asset reporting
Transfer pricing analysis
Tax treaty planning and analysis
Cross-border transaction structuring
Who We Serve
Individuals and businesses with federal, multi-state, or cross-border tax obligations seeking proactive planning and compliance counsel.
-
Navigating the complex tax treatment of litigation proceeds.
The tax consequences of a legal settlement or judgment can be significant — and are often misunderstood. Whether you are a plaintiff, defendant, or attorney, The Karam Firm provides clear, practical guidance on the tax treatment of settlement proceeds, structured settlements, attorney fee allocations, and related reporting obligations.
Representative Services
Tax characterization of settlement proceeds
Physical injury and emotional distress exclusions
Punitive damages and interest taxation
Attorney fee deductibility analysis
Structured settlement tax planning
Form 1099 and W-2 reporting compliance
Employment settlement tax issues
Pre-settlement tax planning for plaintiffs and defendants
Who We Serve
Plaintiffs, defendants, and their counsel seeking clarity on the tax treatment of settlement proceeds, judgments, and related attorney fees.
-
Expert guidance on the rapidly evolving tax landscape for digital assets.
Cryptocurrency and digital asset transactions create complex tax obligations that many taxpayers and advisors are unprepared to handle. The Karam Firm provides sophisticated counsel on the tax treatment of crypto transactions — from trading and mining to DeFi, NFTs, and hard forks — as well as representation in IRS crypto enforcement actions.
Representative Services
Cryptocurrency gain and loss reporting
Mining and staking income tax treatment
DeFi and yield farming tax analysis
NFT tax characterization and reporting
Hard fork and airdrop tax treatment
IRS crypto audit and enforcement defense
Voluntary disclosure for unreported crypto income
Crypto-to-crypto exchange tax analysis
Who We Serve
Investors, traders, miners, and businesses involved in cryptocurrency and digital assets who need expert tax guidance and compliance support.
-
Resolving tax debt and compliance issues before they escalate.
Unresolved tax liabilities and compliance failures can lead to liens, levies, wage garnishments, and — in serious cases — criminal referral. The Karam Firm helps individuals and businesses get compliant, negotiate with the IRS, and resolve outstanding tax debts through the most favorable available resolution.
Representative Services
Currently not collectible (CNC) status requests
Installment agreement negotiation
Offers in Compromise
Federal tax lien discharge and subordination
Levy release and wage garnishment relief
Trust fund recovery penalty defense
Delinquent return filing assistance
IRS Voluntary Disclosure Program (VDP)
Who We Serve
Individuals and businesses with outstanding IRS tax liabilities, unfiled returns, or collection actions who need experienced counsel to resolve their situation.
-
Tax-efficient structuring for your most significant transactions.
The tax consequences of a business sale, merger, or acquisition can dwarf all other transaction costs — making experienced tax counsel essential from the earliest stages of deal planning. The Karam Firm provides integrated M&A tax advice, helping buyers and sellers structure transactions to minimize tax liability and avoid costly surprises at closing.
Representative Services
Asset vs. stock sale analysis
Tax-free reorganization structuring
Section 338 and 336(e) elections
Purchase price allocation (Section 1060)
Earnout and contingent consideration tax treatment
M&A tax due diligence
Representations and warranties tax issues
Post-closing tax dispute resolution
Who We Serve
Business owners, buyers, private equity sponsors, and their advisors seeking experienced tax counsel for mergers, acquisitions, and business sales.
-
Expert guidance on the establishment and administration of QSFs.
Qualified Settlement Funds (QSFs) provide defendants and their insurers with a powerful tool for resolving multi-claimant litigation — allowing the transferor to take a tax deduction at the time of funding while claimants retain flexibility in structuring their recoveries. The Karam Firm advises on the establishment, administration, and tax compliance of QSFs.
Representative Services
QSF establishment and court approval
QSF tax compliance (Form 1120-SF)
Transferor deduction planning
Claimant allocation and distribution planning
Structured settlement integration
Attorney fee QSF planning
Mass tort and class action QSF administration
QSF termination and wind-down
Who We Serve
Defendants, insurers, and plaintiffs' counsel in multi-claimant litigation seeking to establish and administer a Qualified Settlement Fund.
-
Sophisticated counsel for pass-through entity tax matters.
Pass-through entities — partnerships, LLCs, LLPs, and S corporations — offer significant tax advantages but also present complex planning and compliance challenges. The Karam Firm provides sophisticated counsel on the formation, operation, restructuring, and dissolution of pass-through entities, as well as representation in disputes involving these structures.
Representative Services
Partnership and LLC tax planning
Operating agreement tax provisions
Special allocations and substantial economic effect
Basis and at-risk limitation planning
Passive activity loss planning
S corporation elections and compliance
Built-in gains tax planning
Partnership audit rules (BBA) representation
Who We Serve
Business owners, investors, and their advisors seeking sophisticated tax counsel for partnership, LLC, and S corporation matters.
-
Comprehensive tax counsel for mission-driven organizations.
Tax-exempt organizations face a unique set of tax obligations and compliance requirements — from initial exemption applications through ongoing reporting, unrelated business income, and private foundation rules. The Karam Firm provides comprehensive tax counsel to nonprofits, foundations, and other tax-exempt entities.
Representative Services
IRS exemption applications (Form 1023/1024)
Public charity vs. private foundation analysis
Unrelated business income tax (UBIT) planning
Private foundation excise tax compliance
Intermediate sanctions and excess benefit transactions
Form 990 review and compliance
State charitable registration and compliance
Tax-exempt bond financing
Who We Serve
Nonprofits, foundations, trade associations, and other tax-exempt organizations seeking expert tax counsel and compliance support.
-
Resolving worker classification disputes before they become catastrophic.
Worker misclassification is one of the most aggressively enforced areas of tax law — with exposure that can include back taxes, penalties, and personal liability for responsible parties. The Karam Firm represents businesses and individuals in IRS and state worker classification disputes, and provides proactive counsel to help clients structure their workforce relationships correctly.
Representative Services
IRS worker classification audits (SS-8)
Section 530 relief claims
Voluntary Classification Settlement Program (VCSP)
State employment tax classification disputes
Retroactive reclassification defense
Trust fund recovery penalty defense
Independent contractor agreement review
Workforce restructuring tax planning
Who We Serve
Businesses and individuals facing IRS or state worker classification disputes, or seeking proactive counsel to structure their contractor relationships correctly.
-
Experienced defense when tax matters turn criminal.
Federal tax crimes — including tax evasion, filing false returns, and failure to pay — carry severe consequences including substantial fines and imprisonment. The Karam Firm provides experienced defense representation in federal tax crime investigations and prosecutions, working to protect clients' rights and achieve the best possible outcome.
Representative Services
Tax evasion defense (26 U.S.C. § 7201)
Filing false returns defense (§ 7206)
Failure to pay or collect tax defense (§ 7202)
IRS Criminal Investigation (CI) representation
Grand jury subpoena response
Voluntary disclosure to avoid prosecution
Sentencing mitigation
Civil tax liability resolution alongside criminal defense
Who We Serve
Individuals and businesses under investigation by IRS Criminal Investigation or facing federal tax crime charges who need experienced criminal tax defense counsel.
-
Navigating the tax and legal complexities of third-party litigation finance.
Third-party litigation funding has grown rapidly — and with it, a host of unresolved tax questions for funders, plaintiffs, and their counsel. The Karam Firm advises clients on the tax treatment of litigation funding arrangements, including the characterization of funding proceeds, repayment obligations, and the tax consequences of funded settlements and judgments.
Representative Services
Tax characterization of litigation funding proceeds
Funder return tax treatment
Plaintiff tax planning for funded litigation
Attorney fee tax issues in funded matters
Structured repayment tax planning
QSF integration with litigation funding
Disclosure and reporting obligations
Cross-border litigation funding tax issues
Who We Serve
Litigation funders, plaintiffs, and attorneys involved in third-party litigation finance arrangements seeking clarity on the tax treatment of funding proceeds and returns.
Ready to Protect What Matters Most?
Schedule a consultation today and discover how The Karam Firm can provide the strategic legal counsel your situation demands.
P: (702) 550-8805 (Call or Text)
Important Notice Before Submitting This Form
Submitting this form does not create an attorney-client relationship with The Karam Firm, PLLC or any attorney at the firm. No attorney-client relationship is formed unless and until the firm has completed a conflict-of-interest review, agreed in writing to represent you, and you have signed a written engagement agreement.
Please do not submit confidential, privileged, sensitive, or highly detailed information through this form. The purpose of this form is only to allow the firm to determine whether it may be able to assist you and whether a consultation may be appropriate. You should provide only general information, such as your name, contact information, the type of tax issue involved, the taxing authority involved, relevant deadlines, and a brief description of the matter.
Information submitted through this form may be reviewed to evaluate whether the firm can consider a potential representation, including whether any conflict of interest exists. The firm is not obligated to keep information confidential unless required by applicable rules of professional conduct or unless an attorney-client relationship is later established by written agreement.
By submitting this form, you acknowledge and agree that:
You are not becoming a client of The Karam Firm, PLLC;
The firm has not agreed to represent you;
You should not rely on the submission of this form as legal or tax advice;
You remain responsible for all applicable deadlines, including IRS, state tax, court, administrative, appeal, protest, refund-claim, and response deadlines; and
The firm may decline the representation for any reason, including a conflict of interest.
If your matter involves an urgent deadline, you should contact legal counsel immediately and should not wait for a response to this form.