Federal tax controversy · Technical review
GWD helps employers and professional advisors assess compensation, benefits, and employment-tax exposure; organize the facts; and respond to federal tax examinations and administrative disputes. Select a service area to see common triggers and the support available.
IRS examination and administrative dispute
Employment-tax examinations can connect worker status, wage characterization, withholding, payroll deposits, tax returns, information reporting, and employer records. GWD helps identify the issue under development and organize a fact-based federal tax response.
Common pain points
How GWD can help
Possible work product: issue and exposure matrix, record-gap list, chronology, IDR response index, technical analysis, and response or Appeals strategy. Direct IRS representation requires a separate engagement and appropriate authorization.
S corporation employment-tax controversy
When a shareholder performs services and receives distributions, payments, benefits, or other economic value, the IRS may question how the amounts were characterized and reported. These disputes can reach beyond income tax to payroll taxes, deposits, information returns, interest, and penalties.
What may trigger the issue
Review and controversy support
GWD evaluates and supports a tax controversy or defined review. It does not provide a guaranteed “reasonable salary,” manage payroll, or implement compensation changes. See IRS information for S corporation officers.
Federal worker-status matters
Classification turns on the working relationship and facts, not only the contract label or the form used to report a payment. A change in classification can affect federal employment taxes, withholding, reporting, and multiple prior periods.
Common triggers
How GWD can help
State wage, unemployment, labor-law, and benefits questions may use different tests and may require state counsel or other specialists. Program eligibility and contact with the IRS require matter-specific analysis.
Urgent collections and penalty exposure
Unpaid employment taxes can lead to accelerated collection activity, deposit penalties, liens or levies, and questions about personal responsibility for withheld taxes. These cases often arise during cash stress, shutdowns, ownership changes, or restructuring.
Common pain points
How GWD can help
Possible work product: quarter-by-quarter liability timeline, payment reconciliation, record index, procedural issue list, and response plan. GWD does not provide legal defense or criminal representation.
Compensation, equity, and benefits in tax controversy
An executive arrangement may affect employee income, employer deductions, payroll withholding, information reporting, and financial statements at the same time. GWD reviews the federal tax position and examination record when these issues arise in an audit, proposed adjustment, or defined risk review.
Issues that may surface
How GWD can help
GWD does not design or draft compensation plans, award agreements, or equity programs, and does not manage or administer them. Legal interpretation and plan-document work should be handled by qualified counsel or plan specialists.
Taxable benefits and wage reporting
Benefits and expenses can be deductible to an employer and still require employee income inclusion or payroll reporting. The risk grows when benefits data is split across accounts payable, expense systems, payroll codes, HR records, and tax returns.
Common pain points
Review and controversy support
GWD’s role is review, analysis, and controversy support. The employer and its payroll or benefits providers retain responsibility for system changes, payroll processing, filings, and implementation.
Records and information returns
Inconsistent data across HRIS, payroll, accounts payable, equity administration, benefits, and the general ledger can make an otherwise explainable position difficult to defend.
The problem
The support
Affordable Care Act reporting matters
An IRS Letter 226-J or information-reporting notice can require a response grounded in employee-month data, coverage offers, affordability, payroll hours, and enrollment records.
Why a notice can be difficult
How GWD can help
GWD does not administer health plans, determine benefit eligibility, or replace the employer’s ACA reporting vendor. Plan administration and broader benefits-law questions may require other specialists.
Tax-focused retirement plan issue support
Missed eligibility, deferrals, matching contributions, compensation definitions, or plan-year data can create federal tax and reporting questions. A prompt, organized record can help clarify the issue and which specialists need to address it.
Common pain points
How GWD can help
GWD does not administer plans, amend plan documents, submit correction applications, or implement plan corrections. Plan interpretation, fiduciary advice, and correction execution belong with qualified benefits counsel or plan specialists.
Federal compensation tax matters
Hospitals, universities, and other applicable tax-exempt organizations may need to assess executive compensation across related entities, deferred amounts, severance, and reporting.
Potential triggers
How GWD can help
Governance, fiduciary-duty, and nonprofit-law advice are outside GWD’s scope and may require qualified legal counsel.
Transaction-driven tax review
A buyer, investor, lender, or restructuring team may uncover historical owner-pay, payroll, benefit, equity, or deferred-compensation issues. Transaction timing can make it important to understand the federal tax facts before records disperse or payments occur.
Issues that surface
Defined review support
GWD provides tax review and advisory support. Transaction structuring, securities matters, legal opinions, and plan design or implementation require the appropriate specialists.
Related corporate review and advisory
George’s corporate background supports an informed review of company-prepared materials involving share-based compensation and income tax accounting. This work is separate from GWD’s primary IRS controversy practice.
ASC 718
Review company-prepared workpapers and analyses concerning stock-based compensation, related tax effects, and consistency with supporting information. Advisory discussions can identify questions for management, auditors, or legal and valuation specialists.
ASC 740
Review selected tax provision materials, deferred-tax schedules, tax-return-to-provision reconciliations, or compensation-related tax positions. Identify observations and questions for the company’s accounting and tax teams.
Scope boundary: review and advisory only. GWD does not prepare or maintain accounting records, operate the tax provision, administer equity plans, implement accounting processes, or assume management’s responsibilities. No audit, review, attestation, or assurance opinion is provided.
A practical deliverable
For the agreed scope, GWD can organize the facts, identify the issue, note supporting authority and procedural considerations, flag missing information, and present a prioritized response path. The employer and its retained professionals decide what action to take and remain responsible for filings, payroll operations, plan administration, accounting records, and implementation.
GWD is not a law firm and does not provide legal advice or courtroom representation. Matters before the Department of Labor, state or local agencies, or courts may require separate counsel or specialists. Direct IRS representation is available only under a separate engagement and appropriate authorization.
Start with a defined review
Share a general description, organization type, and response deadline. Do not send taxpayer identification numbers, returns, transcripts, payroll files, or other sensitive records through this website or ordinary email.
