Trusted Tax Counsel for Large Employers Navigating Payroll Tax Compliance
At Fuller Tax Law Group, we provide sophisticated counsel on federal payroll tax compliance and employment tax controversy—grounded in decades of IRS National Office leadership experience. Our attorneys helped shape many of the very rules that govern employment tax today, including drafting and interpreting key safe harbors, administrative relief frameworks, and penalty mitigation provisions under Subtitle C of the Internal Revenue Code. This includes the full spectrum of federal payroll taxes: FICA (OASDI/Medicare), FUTA, RRTA, and federal income tax withholding (FITW).
As a boutique law firm, we serve as a strategic partner to Fortune 500 companies and large employers facing complex, high-stakes payroll tax audits. We combine technical precision, historical regulatory insight, and business-aligned execution to deliver practical solutions where payroll tax compliance, IRS audits, and corporate payroll operations intersect.
Our work often focuses on payroll tax risks arising from employee fringe benefits and independent contractor misclassification—two of the IRS’s top audit priorities. No U.S. employer is exempt from these federal payroll tax requirements, making proactive compliance essential.
Technical Depth. Practical Solutions. Proactive Risk Management.
We advise large employers on a full range of payroll tax matters, including:
- FICA tax compliance and strategic risk management
- Worker classification relief, including Section 530, the IRS CSP program, and VCSP filings
- Payroll tax penalties, such as late deposit penalties, and penalty abatement advocacy
- Form W-2 and 1099 compliance, including wage reporting errors and corrections
- Payroll tax refunds, interest-free adjustments, and amended return claims
- Corporate aircraft travel compliance, including SIFL valuations
- Deferred compensation taxation (Section 3121(v)) and supplemental unemployment benefit (SUB/SUB-Pay) plans
- Payroll tax compliance in mergers, acquisitions, and corporate reorganizations
- Settlement payment reporting for employment-related litigation
- B Notices, EIN discrepancies, and internal payroll tax audits
End-to-End Representation from IRS Audit to Resolution
Whether proactively assessing your payroll tax risks or responding to an IRS audit, Fuller Tax Law Group provides enterprise-grade support with the responsiveness and discretion of a boutique firm.
Our team represents clients throughout the entire IRS examination process, including:
- Responding to IRS information requests and document subpoenas
- Preparing executives and payroll personnel for IRS agent interviews
- Drafting IRS Appeals protests and seeking administrative resolutions
- Supporting mediation, technical conferences, and litigation strategy in complex cases
We frequently collaborate with in-house tax and payroll teams, general counsel, and outside law firms to protect our clients’ interests during critical IRS examinations and court proceedings.
Your Partner in Employment Tax Compliance and Defense
Whether facing a targeted IRS audit, evaluating payroll tax risks across your enterprise, or building scalable compliance programs, Fuller Tax Law Group delivers highly tailored solutions that align with your business objectives.
Reach out today to learn how our depth of IRS experience and practical insight can help safeguard your business against payroll tax risk.
Whether you’re facing an employment tax audit, assessing payroll tax risk, or implementing scalable compliance frameworks, The Fuller Tax Law Group delivers highly tailored, enterprise-grade solutions with the responsiveness and discretion of a boutique firm.
