Michael J. Scarduzio focuses his practice on US and international tax matters, particularly civil and criminal tax litigation. From audit to litigation, he represents taxpayers in all phases of tax controversy, including novel issues of first impression such as financial hedging transactions using a captive insurer, US tax implications of a foreign master-feeder fund’s investment activities and matters arising under Internal Revenue Code (IRC) Sections 7216 and 7212(a).

Michael has experience handling a variety of complex tax issues, including partnership audit procedures under the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA) and the Bipartisan Budget Act of 2015 (BBA), international tax and Report of Foreign Bank and Financial Accounts (FBAR) compliance, reportable transactions, transfer pricing, debt equity classifications, foreign tax credits and excise tax on reinsurers. He also advises on questions relating to the attorney-client and work product privileges arising in tax matters.

After law school, Michael served as a term law clerk for the Honorable Karen L. Hayes of the US District Court for the Western District of Louisiana. He also served as a judicial intern for the Honorable Dolores K. Sloviter of the US Court of Appeals for the Third Circuit during law school. And, while earning his LLM in Tax from NYU, he served as a legal extern for the Internal Revenue Service’s (IRS) Office of Chief Counsel and Large Business and International Division in New York.

Michael has contributed to several publications, including co-authoring articles in the Journal of Tax Practice & Procedure addressing potential abuse of CARES Act tax relief provisions, the BBA centralized partnership audit regulations, and the repeal of the TEFRA audit regime. He has also co-authored an article examining the United States’ role as a potential tax haven, published in The Champion.

Charles (Chuck) Moll focuses his practice on state and local tax (SALT), primarily concentrating on the resolution of tax controversies. He regularly appears before the various California tax authorities—including the State Board of Equalization, the California Franchise Tax Board, the California Department of Tax and Fee Administration, and the Office of Tax Appeals—as well as local authorities such as assessors and assessment appeals boards. He has litigated at all levels of California’s courts, the US Tax Court, and the US Supreme Court.

Chuck’s practice includes tax matters in other states, as well as federal tax controversies, including representation of clients in federal courts and at appellate hearings before the Internal Revenue Service.

Charles (Chuck) Moll focuses his practice on state and local tax (SALT), primarily concentrating on the resolution of tax controversies. He regularly appears before the various California tax authorities—including the State Board of Equalization, the California Franchise Tax Board, the California Department of Tax and Fee Administration, and the Office of Tax Appeals—as well as local authorities such as assessors and assessment appeals boards. He has litigated at all levels of California’s courts, the US Tax Court, and the US Supreme Court.

Chuck’s practice includes tax matters in other states, as well as federal tax controversies, including representation of clients in federal courts and at appellate hearings before the Internal Revenue Service.