Tax Research


We have extensive experience in Tax Research. We examine the primary and secondary sources of income tax law, the IRC, and the administrative and judicial interpretations. We carefully explain the tax issues with our clients to ensure they fully understand their tax situation.

We review the Internal Revenue Code, Treasury Department regulations, and any interpretations, rulings, and procedures issued by the Treasury department and/or the Internal Revenue Service (IRS). We analyze Court interpretations and provide citation update services for your case to confirm the law is still current with respect to your issue. We discuss with the client our recommendation on the handling a particular tax matter; and examine the relationship of tax law, IRS interpretations, and relevant case law with you. We discuss the types of tax planning transactions such as:

Open-Fact Tax Planning – In an open-fact transaction, the transaction has not been completed as the facts have not yet been fully established. The transaction is in the early formative or projected stage. There is still an opportunity to plan anticipated facts to get a better tax result. As an example, if an agreement for the sale has not yet been signed, the taxpayer can still structure the agreement (modify the facts) so that the tax consequences of the transaction are more favorable. That is, with this type of transaction, modifications can be made before the transaction is closed to obtain a more favorable tax treatment.

Closed-Fact Tax Planning – In a closed transaction, all of the facts have been completed as the transaction has occurred; therefore tax planning may be limited to the presentation of the facts to the IRS in a more favorable, legally acceptable manner. The confusion with this type of tax planning transaction is the unfound belief that the consequences to the taxpayer are fully determined without any tax research and no additional tax planning is possible. That may not be the case. At times additional through research will uncover support for a legislative, administrative or judicial tax law position that provides an opportunity to legally lower the taxpayers tax liability. At TCS, we fully research the transaction and only then do we focus on how to present the information in a taxpayer positive legally acceptable manner to the IRS.

It is very important to understand that a significant part of tax research for both open and closed transactions is not only to fully gather and understand the facts but the thoroughness of the tax research. Without excellent tax research skills, tax planning, whether open or closed can cause considerable problems for a client.

Many clients are unaware of how important their tax professional’s tax research skills are to their financial tax health. As part of our tax research we use the following three step process:

Legislative Law – We review legislative law. This includes review of tax statutes passed by Congress, its legislative history which may include committee and conference reports, predecessor statutes, statements made in floor debates, earlier versions of the bill and the fact of their change, comments bill sponsors make upon introduction of the bill, etc. We carefully select the extent and depth of legislative law research based on your facts and the tax issue under review.

Administrative Law – We review administrative law, the IRS position on tax law to fully understand the IRS position on your tax issue. The IRS has provided in the past years anywhere from 10-20 different types and forms of guidance. Examples of the different types and forms of guidance we may review include Treas. Reg., Rev. Rulings, Rev. Procedures, Notices and Announcements, Private letter rulings, Technical Advice Memorandums, General Counsel Memoranda, Chief Counsel Advice, Determination Letters, etc.

Judicial Law – We then carefully examine judicial law where a taxpayer has challenged the IRS. We review the usefulness of tax holdings from other tax cases by applying, if possible, the holding to your facts. This is known as analogical legal reasoning. We review Tax Court, District Court, Court of Federal Claims, and Supreme Court rulings to determine the applicable rules and doctrines under judicial tax law.

Let Tax Client Services help you with any tax research needs!

Dirk Wierema


“As the Corporate Controller at Ampro Computers, I hired James to prepare and update four years of amended corporate Federal and State tax returns. While on this project James expertise in Federal and State taxes helped to defer a significant tax liability for our company. James was very easy to work with and took the time to explain complex tax regulations in a way that was easy to understand. I would highly recommend James.”

Controller – Zetta, Inc.

2014-05-14T12:15:06+00:00
“As the Corporate Controller at Ampro Computers, I hired James to prepare and update four years of amended corporate Federal and State tax returns. While on this project James expertise in Federal and State taxes helped to defer a significant tax liability for our company. James was very easy to work with and took the time to explain complex tax regulations in a way that was easy to understand. I would highly recommend James.” Controller – Zetta, Inc.

Howard Chen


“Jim has strong technical skills in the tax field. He is very independent and hard working. Jim gets the job done!”

VP, Corporate Development and Strategy at Bank of the West

2014-05-14T12:14:08+00:00
“Jim has strong technical skills in the tax field. He is very independent and hard working. Jim gets the job done!” VP, Corporate Development and Strategy at Bank of the West

Benny Lee


“A person’s expertise can be differentiated in terms of the following classes: Novice, Beginner, Intermediate, Expert, and World-Class Guru.
My observation of Jim’s practice and understanding of all tax intricacies both from corporate and individual would place him in the class of a World-Class Guru.”

Vice President, Information Technology – East West Bank

2014-05-14T12:01:56+00:00
“A person’s expertise can be differentiated in terms of the following classes: Novice, Beginner, Intermediate, Expert, and World-Class Guru. My observation of Jim’s practice and understanding of all tax intricacies both from corporate and individual would place him in the class of a World-Class Guru.” Vice President, Information Technology – East West Bank

Mike Ford


“I’ve known James Duffy for over thirty years and rely on him for rock solid tax and accounting advice and the very latest in clever AND LEGITIMATE solutions to complex situations. I am very comfortable referring him to my associates and friends and know they will receive the same high standard of care he delivers to his national clients, and to me. He never fails to go the extra mile and has always been a proactive part of every situation I have dragged him into. While many consultants see clients as mere engagements his style is much more comprehensive and it’s not unusual at all to get an email from him at an odd hour treating the topic we’ve been kicking around. I am confident that he is the best of the best.”

Real Estate Professional

2014-05-16T05:01:37+00:00
“I’ve known James Duffy for over thirty years and rely on him for rock solid tax and accounting advice and the very latest in clever AND LEGITIMATE solutions to complex situations. I am very comfortable referring him to my associates and friends and know they will receive the same high standard of care he delivers to his national clients, and to me. He never fails to go the extra mile and has always been a proactive part of every situation I have dragged him into. While many consultants see clients as mere engagements his style is much more comprehensive and it’s not unusual at all to get an email from him at an odd hour treating the topic we’ve been kicking around. I am confident that he is the best of the best.” Real Estate Professional

Pat Powers


“James identified a difficult and complex tax issue that required resolution. This particular issue was unusual and potentially quite troublesome. James supervised analysis and resolution of this issue in a very professional manner. His handling of the issue demonstrated a very good grasp of highly complex legal issues balanced by sound and mature judgment.”

Tax Partner at Baker & McKenzie

2014-05-14T12:05:55+00:00
“James identified a difficult and complex tax issue that required resolution. This particular issue was unusual and potentially quite troublesome. James supervised analysis and resolution of this issue in a very professional manner. His handling of the issue demonstrated a very good grasp of highly complex legal issues balanced by sound and mature judgment.” Tax Partner at Baker & McKenzie

Raffaele Mari


“James is a seasoned tax professional who has excellent technical and communication skills. He is a quick study and focuses on providing value-added services. He is a team player who is willing to do whatever it takes to deliver results in a cost-effective manner. I have enjoyed the opportunity to work with James and am confident that anyone would be very satisfied with his work.”

Managing Director, Global Wealth Management

2014-05-14T12:12:00+00:00
“James is a seasoned tax professional who has excellent technical and communication skills. He is a quick study and focuses on providing value-added services. He is a team player who is willing to do whatever it takes to deliver results in a cost-effective manner. I have enjoyed the opportunity to work with James and am confident that anyone would be very satisfied with his work.” Managing Director, Global Wealth Management

Silina Dudkina

I have great respect for James and his firm Tax Client Services. He is personable, trustworthy and frankly brilliant in his field. His tax and accounting experience, knowledge and ethical character are of the highest standards. He has the ability to focus on key tax issues that make a difference that is rarely seen these days. Its hard to find a CPA who is highly competent, who you can trust, and one that will not over-charge you! His many strengths include how determined and focused he is in taking care of his clients tax and accounting problems. James is a polished and experienced tax professional, one whom you can count on to go the extra mile and who will do everything possible to ensure his clients pay the absolute minimal amount of taxes possible. I highly recommend this tax professional!

Studying to be a Nurse

2014-05-14T12:09:40+00:00
I have great respect for James and his firm Tax Client Services. He is personable, trustworthy and frankly brilliant in his field. His tax and accounting experience, knowledge and ethical character are of the highest standards. He has the ability to focus on key tax issues that make a difference that is rarely seen these days. Its hard to find a CPA who is highly competent, who you can trust, and one that will not over-charge you! His many strengths include how determined and focused he is in taking care of his clients tax and accounting problems. James is a polished and experienced tax professional, one whom you can count on to go the extra mile and who will do everything possible to ensure his clients pay the absolute minimal amount of taxes possible. I highly recommend this tax professional! Studying to be a Nurse

Blake Christian


“James hired our firm to evaluate UCB’s California Enterprise Zone Credits. James proved to be a highly technical, high quality, tax executive and was very helpful in managing a complex, multi-year, project. With James assistance, we were able to jointly identify over $6M of supplemental tax savings for his bank.”
Tax Partner, HCVT LLP

2014-05-14T11:57:59+00:00
“James hired our firm to evaluate UCB’s California Enterprise Zone Credits. James proved to be a highly technical, high quality, tax executive and was very helpful in managing a complex, multi-year, project. With James assistance, we were able to jointly identify over $6M of supplemental tax savings for his bank.” Tax Partner, HCVT LLP

Wesley Wakeford


“James Duffy has advised me on several tax matters. I give him my highest recommendation for his knowledge of tax law, for having the highest integrity and also for being a true gentleman. James is a very sharp intellectual and is also a very creative professional. If you need tax help, you will not go wrong with James Duffy.”

Attorney

2014-05-14T12:07:08+00:00
“James Duffy has advised me on several tax matters. I give him my highest recommendation for his knowledge of tax law, for having the highest integrity and also for being a true gentleman. James is a very sharp intellectual and is also a very creative professional. If you need tax help, you will not go wrong with James Duffy.” Attorney

George Baker


“James was hired because of his outstanding tax expertise. He worked on tax issues related to financial statement documents backing the bank’s submission of its 10-K, 10-Q and other SEC submissions. He was responsible for tax compliance and filings for a $6 Billion market cap company. His knowledge of the tax law led to substantial savings for the bank. One example was the bank’s foreign earnings repatriation strategy–$8 million in federal taxes were saved as well as some $2 million in state taxes. James is a master at sorting through details on tax issues and used this to reach correct tax applications to the benefit of the bank.”

Senior Vice President at Zions Bank

2014-05-14T12:04:36+00:00
“James was hired because of his outstanding tax expertise. He worked on tax issues related to financial statement documents backing the bank’s submission of its 10-K, 10-Q and other SEC submissions. He was responsible for tax compliance and filings for a $6 Billion market cap company. His knowledge of the tax law led to substantial savings for the bank. One example was the bank’s foreign earnings repatriation strategy–$8 million in federal taxes were saved as well as some $2 million in state taxes. James is a master at sorting through details on tax issues and used this to reach correct tax applications to the benefit of the bank.” Senior Vice President at Zions Bank

Irina Butorina



“James has been helping me with my taxes since 2010 and I am happy about how effective his solutions are and most important – I am very happy with the money he saves for me. His ability to focus on taxes like nobody I have ever seen is actually amazing. He asks a lot of questions always looking for ways to lower my taxes. Don’t be surprised to get detailed emails discussing your issues without any charge on his part at odd hours of the day or night. He cares about his work and I have been always amazed at how he comes up with tax ideas that really work and are legal which is a very important thing for me. He is friendly and fast thinking and returns your phone call promptly, is easy to reach, and will make sure you pay the least amount of taxes possible. He is a God sent tax geek and I would highly recommend James to anyone of my friends.”
Doctor of Medicine

2014-05-14T12:16:15+00:00
“James has been helping me with my taxes since 2010 and I am happy about how effective his solutions are and most important – I am very happy with the money he saves for me. His ability to focus on taxes like nobody I have ever seen is actually amazing. He asks a lot of questions always looking for ways to lower my taxes. Don’t be surprised to get detailed emails discussing your issues without any charge on his part at odd hours of the day or night. He cares about his work and I have been always amazed at how he comes up with tax ideas that really work and are legal which is a very important thing for me. He is friendly and fast thinking and returns your phone call promptly, is easy to reach, and will make sure you pay the least amount of taxes possible. He is a God sent tax geek and I would highly recommend James to anyone of my friends.” Doctor of Medicine

Juan Carlos Villalobos


“I contacted James Duffy at Tax Client Services to have him prepare the financial statements and tax returns for Aapex Financial Solutions, LLC. He did a great job preparing my friend’s tax return, significantly reducing their tax liability. They were impressed on how detailed he was as he looked at all of the tax planning techniques allowed under the tax law. My friends liked that he looks at your prior year tax returns to determine if there are any missed tax deductions without any up-front charge. He then found a lot of tax savings! With that background I had no issues asking for his assistance on this project. He helped me on issues with the California Residential Mortgage division, the US department of HUD, reviewed my prior year financial statements and tax returns, etc. He identified important issues in the prior and current year tax returns. It is a given that I will continue with his services. He is a very accomplished professional and a pleasure to work with. I highly recommend Tax Client Services!”

President at Aapex Financial Solutions, LLC

2014-05-14T12:10:46+00:00
“I contacted James Duffy at Tax Client Services to have him prepare the financial statements and tax returns for Aapex Financial Solutions, LLC. He did a great job preparing my friend’s tax return, significantly reducing their tax liability. They were impressed on how detailed he was as he looked at all of the tax planning techniques allowed under the tax law. My friends liked that he looks at your prior year tax returns to determine if there are any missed tax deductions without any up-front charge. He then found a lot of tax savings! With that background I had no issues asking for his assistance on this project. He helped me on issues with the California Residential Mortgage division, the US department of HUD, reviewed my prior year financial statements and tax returns, etc. He identified important issues in the prior and current year tax returns. It is a given that I will continue with his services. He is a very accomplished professional and a pleasure to work with. I highly recommend Tax Client Services!” President at Aapex Financial Solutions, LLC

Mona Sheung


“James is a very hard working and diligent, someone I respect and trust!"

ControllerClient Service Manager at FIOH Global Asset Management and Strategies, LLC

2014-05-14T12:21:25+00:00
“James is a very hard working and diligent, someone I respect and trust!" ControllerClient Service Manager at FIOH Global Asset Management and Strategies, LLC

Why TCS?

Tax Client Services (TCS) is dedicated to helping you with all of your tax and accounting needs, including maximizing your after-tax cash flow by minimizing your tax liability.

Experience

James was born in Seattle, Washington though he spent the greater portion of his early years in Hawaii. Completing his Bachelor of Economics from the University of Santa Barabar, James was hired by PricewaterhouseCoopers.

Selecting a Tax Professional

When you’re looking for a talented and skillful tax professional, the one thing you absolutely need is to select someone who is well versed in tax law. Not requiring this could cost you greatly in both lost cash flow and additional stress...