Mr. Ben-Cohen is an Attorney-at-Law and a Certified Public Accountant (CPA) who specializes in civil and criminal tax controversy and litigation. Mr. Ben-Cohen is also a Certified Taxation Law Specialist, certified by the State Bar of California Board of Legal Specialization. Mr. Ben-Cohen represents clients in civil and criminal tax matters, including voluntary disclosures, offshore matters, audits, appeals, litigation, and collection defense. He also assists clients with state and local tax matters, including representation before the California Franchise Tax Board, the State Board of Equalization, and Employment Development Department. Prior to establishing the Ben-Cohen Law Firm, PLC in 2009, Mr. Ben-Cohen was associated with the international law firms of Latham & Watkins, LLP and Gibson, Dunn & Crutcher, LLP. He also gained tax controversy experience working at Deloitte & Touche, LLP and the Tax Division of the U.S. Attorney’s Office. Mr. Ben-Cohen was admitted to the California Bar in 2003. Mr. Ben-Cohen has been named a Rising Star in Tax Law by Super Lawyers from 2009 to 2016, an honor achieved by no more than 2.5 percent of the lawyers in California. In addition, Mr. Ben-Cohen ranked in the top 100 of the Up-And-Coming Rising Stars by Super Lawyers in 2015. He is also a member of the Tax Section of the American Bar Association.
· Mr. Ben-Cohen represents numerous taxpayers who are voluntarily disclosing to the IRS offshore bank accounts and related income tax liabilities.
· Mr. Ben-Cohen represents a number of taxpayers who are being criminally investigated by the Department of Justice for failure to report foreign bank accounts and income earned on those accounts.
· Mr. Ben-Cohen has developed an expertise in sensitive civil tax examinations where fraud or substantial penalty issues may arise.
· Mr. Ben-Cohen handles criminal tax fraud investigations.
· Mr. Ben-Cohen represents taxpayers facing criminal and civil tax disputes with the California Franchise Tax Board and other state and local taxing agencies.
· Mr. Ben-Cohen obtains favorable private letter rulings from the IRS for taxpayers.
Mr. Ben-Cohen earned his law degree cum laude from Georgetown University Law Center. While at Georgetown, Mr. Ben-Cohen was a member of The Tax Lawyer, where he published The Real Estate Exception to the Passive Activity Rules in Mowafi v. Commissioner and the New Burden Shifting Statute, 55 TAX LAW. 96 (2002). Mr. Ben-Cohen has also published Public Civil Defenders: A Right to Counsel for Indigent Civil Defendants, 10 GEO. J. ON POVERTY L. & POL'Y, 1 (2003).He earned a B.S. degree cum laude from the University of Southern California, where he majored in accounting.
Tax Notes International, August 11, 2014
Daily Tax Report, March 9, 2011
· New Safe Harbor For Like-Kind 1031 Exchanges
Real Property Section Review, Los Angeles County Bar Association, Volume V, Issue 4, June 2010
· Public Civil Defenders: A Right To Counsel For Indigent Civil Defendants
By Pedram Ben-Cohen & Simran Bindra - 2003
|Award name||Grantor||Date granted|
|Super Lawyer||Los Angeles Magazine||2016|
|Super Lawyer||Los Angeles Magazine||2015|
|Super Lawyer||Los Angeles Magazine||2014|
|Super Lawyer||Los Angeles Magazine||2013|
|Super Lawyer||Los Angeles Magazine||2012|
|Super Lawyer||Los Angeles Magazine||2011|
|Super Lawyer||Los Angeles Magazine||2010|
|Super Lawyer||Los Angeles Magazine||2009|
|Founder||Ben-Cohen Law Firm, PLC||2009 - Present|
|Attorney||Lathem & Watkin LLP||2006 - 2009|
|Attorney||Gibson, Dunn & Crutcher, LLP||2004 - 2006|
|Association name||Position name||Duration|
|State Bar of California||Taxation Law Specialist||2010 - Present|
|California Board of Accountancy||Certified Public Accountant||2005 - Present|
|State Bar of California||Attorney||2003 - Present|
|Tax Notes International||OVDPs: The IRS Should Put Its Money Where Its Mouth Is||2014|
|Forbes||Pedram Ben-Cohen quoted by Forbes Magazine, Family Secrets -- As the government closes in, the owners of offshore accounts, and their heirs, face legal perils and tricky choices||2014|
|Forbes||Pedram Ben-Cohen quoted by Forbes Magazine, In Reversal, IRS Gives Amnesty To Owners Of Secret Israeli Bank Accounts||2013|
|SonntagsZeitung||Pedram Ben-Cohen quoted by SonntagsZeitung, one of the mostly widely circulated newspapers in Switzerland||2013|
|Bloomberg||Pedram Ben-Cohen quoted by Bloomberg, Bank Leumi, Mizrahi Clients Said to Aid U.S. Tax Probe||2013|
|Daily Tax Report||IRS’s Offshore Bait and Switch: The Case for FAQ 35||2011|
|National Taxpayer Advocate||Fiscal Year 2012 Objectives: Report to Congress (RE: Pedram Ben-Cohen, IRS’s Offshore Bait and Switch: The Case for FAQ 35, 46 DTR J-1 (Mar. 9, 2011))||2011|
|Real Property Section Review, Los Angeles County Bar Association, Volume V, Issue 4||New Safe Harbor For Like-Kind 1031 Exchanges||2010|
|Daily Tax Report||Payments by Majority Shareholders to Minority Shareholders to Secure Change in Control: Ordinary Income or Capital Gain?||2005|
|Daily Tax Report||Consideration of Subject Matter Jurisdiction of District Courts Required When Preparing Cases Where Taxpayers Seek Solely Statutory Interest||2004|
|The Tax Lawyer||Public Civil Defenders: A Right To Counsel For Indigent Civil Defendants||2003|
|The Tax Lawyer||The Real Estate Exception To The Passive Activity Rules In Mowafi v. Commissioner And The New Burden Shifting Statue||2002|
|Georgetown University Law Center||JD - Juris Doctor||2003|
|University of Southern California||BS - Bachelor of Science||N/A|
|2017 33rd Annual Tax Controversy Institute||SHOULD YOUR CANNABIS OR BITCOIN CLIENT CONSIDER TAKING THE FIFTH?||2017|
|CPA||Offshore Bank Account Reporting and Compliance Options||2016|
|CPA Firm||Offshre Voluntary Disclosure Program||2012|
|Foreign Bank Account||Ben-Cohen Law Firm represented Taxpayer in the Offshore Voluntary Disclosure Program. Pedram Ben-Cohen negotiated with the IRS Agent and IRS Technical Advisor to reduce Taxpayer’s offshore penalty from 25% to 5%.|
|Audit||Pedram Ben-Cohen (1) prevented the audit from spreading to earlier and subsequent years, (2) convinced the agent not to refer the case to IRS Criminal Investigation, and (3) closed the audit without assessment of civil fraud penalties.|
|IRS Subpoena||Ben-Cohen Law Firm represented Taxpayer during the criminal investigation and responded to the subpoena. Pedram Ben-Cohen convinced the DOJ attorney handling the investigation to close the investigation and decline prosecution.|
|Secret Account||Ben-Cohen Law Firm advised Taxpayer to file amended returns and delinquent FBARs (a quiet disclosure). Subsequently, Taxpayer was audited by the IRS and Pedram Ben-Cohen closed the examination with no FBAR penalties assessed.|
|Real Estate Lien||I (1) immediately release the levy, (2) fully refund the taxes (plus interest) incorrectly assessed against the partnership, and (3) correct IRS records to reflect that the partnership does not have any foreign partners.|
|Retirement Distribution Audit||Pedram Ben-Cohen filed a Tax Court Petition and concurrently sought a ruling from the IRS waiving the 60-day rollover requirement. Pedram Ben-Cohen was successful in obtaining the ruling and Taxpayer’s retirement savings was not taxed.|
|Offshore Voluntary Disclosure Program||Taxpayers engaged the Ben-Cohen Law Firm to represent them in connection with the examination of Taxpayers’ foreign accounts. Pedram Ben-Cohen closed the examination with no FBAR penalties assessed.|
|IRS Audit||An administrative innocent spouse claim filed with the IRS and appealed. IRS Appeals granted wife partial innocent spouse relief. Mr. Ben-Cohen filed a petition with the United States Tax Court and the IRS granted wife's innocent spouse claim in full.|
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Tue Apr 30 2019
Posted by Em
Mon May 28 2018
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