Tax Strategy
Complex Tax Preparation
Precision Where It Matters.
When your tax situation is too complex for a standard CPA — multi-entity structures, international reporting, high-value transactions — you need tax returns prepared by attorneys who understand the legal implications of every line.
Key Takeaway
For high-income, multi-entity, or internationally exposed taxpayers, a tax return is only as good as the strategy behind it. Attorney-prepared returns integrate legal analysis that CPAs typically don’t provide.
Your Tax Return Is Only as Good as the Strategy Behind It.
Complex tax returns aren’t just about plugging numbers into forms. They’re about making hundreds of elections, classifications, and position decisions — each with legal and financial consequences. The difference between an attorney-prepared return and a standard CPA return is the difference between strategic positioning and mere compliance.
Multi-entity structures, international reporting obligations, high-value transactions, and aggressive tax positions all require preparation by professionals who understand the legal framework — not just the accounting rules.
We prepare returns for clients whose tax situations demand precision: business owners with multiple entities, individuals with international holdings, investors with complex transactions, and anyone whose returns require positions that may face IRS scrutiny.
From Our Practice
In our practice, we prepare returns for clients with eight-figure incomes, multi-entity structures, and international reporting obligations. The difference between a tax-prepared return and a strategy-prepared return can be hundreds of thousands of dollars in legitimate tax savings.
What We Prepare
Tax Preparation Services
Multi-Entity Returns
Coordinated preparation of individual, partnership, S-Corp, and C-Corp returns for business owners with multiple entities, ensuring consistency and optimal positioning across all returns.
International Tax Returns
FBARs, Forms 3520, 5471, 8938, and foreign tax credit calculations prepared by attorneys who understand the penalty exposure of every form.
High-Net-Worth Individuals
Complex individual returns involving investment income, stock options, real estate, trusts, and charitable giving — prepared with an eye toward audit defense.
Transaction-Year Returns
Returns in the year of a business sale, merger, or major transaction require careful reporting of gains, installment treatment, and purchase price allocation.
Amended Returns
When prior returns need correction — whether for compliance, audit settlement, or voluntary disclosure — we prepare amended returns that properly reflect your position.
Audit-Ready Preparation
Every return we prepare is built to withstand IRS scrutiny. We document positions, maintain workpapers, and prepare supporting memoranda for aggressive positions.
Our Approach
Attorney-Prepared Returns: Explained
Why would I hire an attorney to prepare my taxes?
For most taxpayers, a CPA is the right choice. But when your situation involves legal complexity — multiple entities, international reporting, high-value transactions, positions the IRS might challenge, or pending disputes — an attorney-prepared return adds a layer of legal strategy that protects you.
Attorney-prepared returns are also covered by attorney-client privilege, meaning our communications about your return positions cannot be compelled by the IRS. CPA work product does not enjoy this protection.
How is your preparation different from a CPA?
We approach each return as both a compliance document and a strategic document. Every election, every classification, and every position is evaluated for its legal defensibility and its impact on your overall tax strategy — not just for whether it produces the lowest number this year.
We also prepare position memoranda for aggressive positions, documenting the legal basis for each position in a way that provides penalty protection if the IRS disagrees.
Do you work with my existing CPA?
Yes. In many cases, we work collaboratively with your CPA — they handle standard compliance elements while we focus on the complex areas requiring legal judgment. This gives you the best of both worlds: accounting expertise and legal strategy.
Talk to a Tax Attorney
Not Sure Where You Stand?
Schedule a free 15-minute call. We’ll assess your situation, outline your options, and tell you exactly what to expect — no obligation.
or call (619) 378-3138
Why Brotman Law
Tax Preparation Built for Complexity
Attorney Privilege
Our work is protected by attorney-client privilege — CPA work product is not.
Audit-Ready
Every return is prepared to withstand IRS examination, with documented positions and supporting memoranda.
Legal Strategy
We don’t just file — we position. Every return reflects your broader tax strategy and legal objectives.
Multi-Disciplinary
We understand entity law, international tax, transactions, and controversy — all of which inform return preparation.
Precision
Complex returns demand precision. Errors in multi-entity or international returns can trigger severe penalties we work to prevent.
Coordination
We coordinate across all your entities, jurisdictions, and advisors to ensure complete consistency in reporting.
Learn More
Tax Preparation Guides & Resources
Free Guide
Business Tax Optimization
Strategy and preparation work together — optimize before you file.
Read the Guide →
Free Guide
International Tax
International returns require specialized compliance expertise.
Read the Guide →
Free Guide
Individual Tax Strategy
Personal tax planning that informs your return preparation.
Read the Guide →
Free Guide
A comprehensive, attorney-written resource covering everything you need to know about this topic.
Related services: International Tax • International Tax Issues • Multi-State Tax
Also consider: IRS Audits • Criminal Tax Defense
What Makes a Return Complex
Substantive Positions That Need Legal Analysis
“Complex” isn’t a marketing word here. It’s shorthand for returns where the right answer depends on how the law applies to the specific facts, not just plugging numbers into the right boxes. Some of what we actually work through at preparation time:
- Reasonable compensation analysis for S-corp owners under Watson v. Commissioner and the IRS Job Aid — the line between salary and distribution drives both income and self-employment tax exposure.
- Section 199A QBI deduction — specified service trade or business (SSTB) classification, aggregation elections under Reg. §1.199A-4, and the W-2 wage and UBIA limits. The wrong classification can cost 20% of qualifying business income.
- Material participation under §469 — the seven tests, grouping elections, and real estate professional status. Misclassifying activity as active vs. passive is one of the most common audit-magnet errors.
- Basis tracking for partnerships and S corporations — inside vs. outside basis, debt allocations, suspended losses. When the IRS challenges deductions or distributions, basis records are the first thing they ask for.
- Section 1202 qualified small business stock — eligibility, holding period, the per-issuer cap, and packing rules. The exclusion is potentially worth millions and frequently overlooked.
- Foreign disclosure requirements — FBAR (FinCEN 114), Form 8938, Form 5471, Form 8865, Form 3520, Form 3520-A. Penalties for missed filings start at $10,000 per form per year and escalate quickly.
- State sourcing and allocation for multi-state filers — apportionment factors, throwback rules, P.L. 86-272 immunity questions, and California’s market-based sourcing under R&TC §25136.
When the return is prepared in light of the underlying legal authority — and the supporting documentation is built at preparation time, not reconstructed three years later under audit — the entire risk profile changes.
Why Attorney-Prepared
What You Get That a CPA-Only Preparation Doesn’t
Most CPAs prepare excellent returns. The difference with attorney involvement is not about preparation quality — it’s about how the return interacts with downstream legal exposure. Three specific things change:
1. Attorney-client privilege. Communications with your CPA about a return position are not privileged in federal court. Communications with us about that same position generally are. If a return is later examined and the analysis behind a position becomes a litigation issue, that distinction matters.
2. Substantial authority opinions. When a position is uncertain, the difference between “no penalty” and a 20% accuracy-related penalty often turns on whether you had substantial authority for the position under §6662(d). A formal opinion letter — issued by an attorney, citing the relevant authority — can be the documentation that defeats the penalty.
3. Continuity through controversy. When the return is examined, the lawyer who prepared the position is the same lawyer who defends it. No handoff, no learning curve, no document review starting from scratch. The substantive analysis done at preparation time becomes the foundation of the audit defense.
Frequently Asked Questions
Tax Preparation FAQs
How much does attorney-prepared tax returns cost?
Our fees depend on complexity. Multi-entity, multi-state, and international returns cost more than simple individual returns. We provide a fee estimate after reviewing your situation. For most of our clients, the strategic value and audit protection far exceed the incremental cost over standard CPA preparation.
Do you prepare simple individual returns?
Our focus is on complex returns that benefit from legal expertise. For straightforward W-2 individual returns, a CPA is typically the better and more cost-effective choice. We’re the right fit when your situation involves business ownership, international holdings, or significant investment activity.
When should I start working with you on my return?
The earlier the better. We prefer to be involved in tax planning throughout the year so that return preparation is a natural continuation of the strategy. However, we can also prepare returns for clients who come to us during filing season.
Can you help with returns that are already overdue?
Yes. We prepare delinquent returns for all prior years, whether for voluntary compliance or in response to IRS notices. We also handle returns required as part of audit settlements or voluntary disclosure programs.
Do you handle state returns too?
Yes. We prepare returns for California and all other states where you have filing obligations. Multi-state coordination is one of the areas where attorney preparation provides the most value.
What is a tax position memorandum?
A written legal analysis documenting the factual and legal basis for a position taken on your return. It serves as evidence that the position was taken with reasonable cause and in good faith, which is the standard for avoiding penalties if the IRS disagrees with your position.
Get Started Today
Book Your Free 15-Minute Call
Schedule a brief call with our team to discuss your situation. We’ll assess where things stand and outline your options — confidentially and without obligation.
- Completely confidential — protected by attorney-client privilege
- Every situation is different — you’ll receive a custom assessment tailored to yours
- Same-day and next-day appointments available