Disclaimer

All content published on scltaxlaw.com — including articles, blog posts, service descriptions, guides, FAQs, practice area overviews, and any other written materials — is provided for general informational and educational purposes only.

Nothing on this website constitutes legal advice, tax advice, or a legal opinion applicable to your specific facts or circumstances. The information provided:

• Is not tailored to your individual situation, tax history, or legal standing;
• Does not account for changes in IRS regulations, Treasury guidance, or tax court decisions that may have occurred after publication;
• May not apply to residents of states or countries outside California and the United States;
• Is not a substitute for a confidential consultation with a licensed tax attorney;
• Should not be relied upon to make decisions about IRS disputes, offshore accounts, penalty abatement, or any other tax matter.

If you have a specific tax question or are facing IRS action, contact our office directly to speak with an attorney. Proper legal advice is always fact-specific and confidential.

Use of this website, submission of a contact form, or sending an email to Segal, Cohen & Landis, P.C. does not create an attorney-client relationship.

An attorney-client relationship with the Firm is formed only when all three of the following conditions are met:

1. The Firm has performed a conflicts-of-interest check and confirmed it has no conflicts that would prevent representation;
2. The Firm has expressly agreed in writing to represent you; and
3. You have signed a written engagement agreement (retainer) with the Firm.

Until all three conditions are satisfied, information you share through this website or by email is not protected by attorney-client privilege. Please do not submit confidential documents, account numbers, IRS notices, or sensitive financial details through an unsecured web form or email until a signed engagement agreement is in place.

This website is attorney advertising material. Segal, Cohen & Landis, P.C. is a professional law corporation licensed in the State of California. The information contained herein is provided in compliance with the California Rules of Professional Conduct, the California Business and Professions Code, and applicable State Bar of California regulations governing attorney advertising.

Responsible attorney: Samuel Landis, Esq., Segal, Cohen & Landis, P.C., 9100 Wilshire Boulevard, 601 East Tower, Beverly Hills, CA 90212.

Prior results described on this site do not guarantee a similar outcome. Each matter is unique and results depend on the specific facts and applicable law.

If you are located outside California, please be aware that contacting this Firm does not create an attorney-client relationship and that the Firm may not be authorized to practice law in your state or jurisdiction.

Segal, Cohen & Landis, P.C. makes reasonable efforts to ensure the accuracy of the information published on this website. However, we make no representations or warranties — express or implied — as to the completeness, accuracy, reliability, suitability, or availability of any information on the Site.

Tax law is among the most rapidly evolving areas of U.S. law. IRS regulations, Treasury guidance, Revenue Procedures, Chief Counsel Advice, and Tax Court decisions may change the legal landscape significantly between the date an article is published and the date you read it. Content on this site:

• Reflects the law as understood at the time of writing;
• May not be updated to reflect subsequent legislative, regulatory, or judicial changes;
• May omit nuances, exceptions, and threshold amounts that affect your situation;
• Should always be verified against current IRS guidance at irs.gov or through a qualified tax attorney.

Any descriptions of past cases, client outcomes, penalty reductions, settlements with the IRS, or other results mentioned on this website are provided solely as illustrations of the type of work the Firm handles. They are not guarantees that similar results can be obtained in your matter.

The outcome of any tax dispute, IRS audit, collection action, or voluntary disclosure depends on the unique facts of each case, the applicable law at the time, IRS discretion, and many other factors outside any attorney’s control. Testimonials from past clients, where shown, reflect individual experiences and are not representative of all outcomes.

U.S. federal tax law — including the Internal Revenue Code, IRS regulations, Treasury guidance, FBAR rules under the Bank Secrecy Act, and FATCA requirements — is subject to frequent change. International tax law, including tax treaties, OECD BEPS frameworks, and foreign reporting obligations, is similarly dynamic.

Threshold amounts (such as FBAR filing thresholds, Form 3520 reporting thresholds, PFIC mark-to-market elections, and penalty caps) change periodically based on inflation adjustments, statutory amendments, and IRS administrative guidance. Always verify current thresholds and requirements with an attorney before acting.

The Firm is not responsible for any action taken or omitted based on information that was accurate when published but has since changed.

Segal, Cohen & Landis, P.C. is a California professional law corporation. Our attorneys are licensed to practice law in California and, where indicated, before the United States Tax Court and other federal tribunals.

Nothing on this website constitutes an offer to practice law in any state, country, or jurisdiction where the Firm’s attorneys are not admitted. If your matter involves state income tax issues, local tax law, or the laws of a country other than the United States, you should consult an attorney licensed in that jurisdiction.

The Firm routinely represents clients with international tax issues — including U.S. citizens and green card holders abroad, foreign nationals with U.S. tax obligations, and dual citizens — before the IRS and U.S. federal courts. Such representation is distinct from the practice of foreign law, which the Firm does not provide.

This website and all content are provided on an “as is” and “as available” basis, without warranty of any kind, whether express, implied, or statutory.

Segal, Cohen & Landis, P.C. expressly disclaims all warranties, including but not limited to:

• Implied warranties of merchantability, fitness for a particular purpose, and non-infringement;
• Any warranty that the website will operate uninterrupted, error-free, or free of viruses or other harmful components;
• Any warranty regarding the accuracy, reliability, completeness, or timeliness of any content published on the Site;
• Any warranty that specific legal outcomes can be achieved based on information found on this website.

To the fullest extent permitted by applicable law, Segal, Cohen & Landis, P.C., its attorneys, staff, affiliates, and agents shall not be liable for any direct, indirect, incidental, consequential, special, exemplary, or punitive damages arising out of or in connection with your use of, or inability to use, this website or any content thereon — including but not limited to:

• Reliance on any information published on this Site;
• Any failure to seek timely legal advice;
• Any IRS penalty, assessment, or collection action;
• Errors or omissions in the content;
• Interruptions or failures of the website.

This limitation applies regardless of the form of the action, whether in contract, tort (including negligence), strict liability, or otherwise, even if the Firm has been advised of the possibility of such damages.

Some jurisdictions do not allow the exclusion or limitation of incidental or consequential damages, so the above limitation may not apply to you.

This website may contain links to third-party websites, including IRS.gov, U.S. Tax Court records, government publications, and other external resources. These links are provided for convenience and informational purposes only.

Segal, Cohen & Landis, P.C. does not control third-party websites and is not responsible for their content, accuracy, privacy practices, or availability. A link to a third-party site does not constitute an endorsement or recommendation by the Firm. You access third-party sites at your own risk.

This website is operated in the United States and is governed by U.S. law. If you access this Site from outside the United States, you do so at your own initiative and are responsible for compliance with your local laws.

The Firm serves clients in many countries, including the United Kingdom, Canada, Israel, Australia, Germany, France, China, Japan, South Korea, the United Arab Emirates, and Brazil. However, information on this website is written primarily from a U.S. federal tax law perspective and does not address the domestic tax laws of other countries. International visitors should consult local counsel for advice on their home-country tax obligations.

For visitors from the European Union: this disclaimer and associated policies are intended to comply with the EU General Data Protection Regulation (GDPR) and Directive 2002/58/EC. For visitors from Canada: these policies are designed to comply with the Personal Information Protection and Electronic Documents Act (PIPEDA).

If you have a tax matter that requires professional legal advice — including IRS audits, tax liens, unfiled returns, offshore account reporting, FBAR penalties, Form 3520 compliance, penalty abatement, or any other federal or international tax issue — please contact our office directly.

Consultations are confidential. Initial consultations do not create an attorney-client relationship until an engagement agreement is signed. For urgent matters, call directly — do not rely on email or web forms.