WeiHsiang (Robert) Su

Researches complex federal and state tax law statutes, regulations, case law, internal revenue manual, private letter rulings, and technical advice memorandums. • Drafts internal-use legal memorandums, IRS submitted IRC 1202 QSBS tax opinions attached to returns, and client advisory letters. • Defends multi-millions of Research and Development Credit for clientele in IRS tax audit, appeals and Tax Court - IRC 41, IRC 174, and IRC 1.41-(1-4A) and drafts letters to IRS area counsel. • Submits Form 656-L Offers in Compromises to the IRS Central Offer In Compromise unit and drafts opinion letters on Complex ASED issues (Assessment Statute Expiration Date) to IRS. • Ensures compliance for taxpayers with international subpart F income and GILTI income. • Drafts and E-files Petitions for Notices of Deficiency, Motions, and proposed stipulated decisions for US Tax Court. • Calculates Statute of Limitations for ASED, CSED, and RSED matters (Assessment, Collections, and Refund) • Negotiates installment agreements for corporations and individuals with IRS and FTB using taxpayer financial information on IRS form 433A, 433B and FTB form 3561C.