WeiHsiang Su

Tax Controversy attorney barred in Texas and District of Columbia specializing in Research and Development Credits

Additional duties preformed:
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