Our Services
Drawing on senior leadership experience at the IRS National Office and as Am Law 100 partners, Fuller Tax Law Group understands how enforcement priorities are set, how examinations escalate, and where statutory and administrative relief can be strategically deployed. Some of these key relief strategies and positions are routinely overlooked by senior IRS personnel and private sector attorneys alike.
We are engaged as specialized counsel to collaborate with in-house tax and legal teams and existing outside advisors on discrete high-impact matters within our core service areas. This focused role strengthens our ability to provide targeted technical depth and strategic perspective while integrating seamlessly into established advisory relationships.
Fuller Tax Law Group strives to deliver an integrated employment tax risk platform that mirrors the IRS’s regulatory and audit framework across three interrelated practice areas: (1) employee noncash fringe benefits, (2) worker classification and contingent workforce compliance, and (3) federal payroll tax compliance. Our three core service areas, in turn, are supported by a coordinated audit defense that pursues targeted relief strategies when issues arise. These disciplines rarely operate in isolation — scrutiny in one frequently creates exposure in another.
Most tax disciplines concentrate primarily on entity-level tax consequences. In these three practice areas, the financial, reputational, and governance impact on executives and the broader workforce can be as significant as—or greater than—the impact on the business itself. IRS examinations in these interrelated areas often implicate these multiple stakeholders—placing a premium on heightened coordination and thoughtful planning. We strive to align strategic planning, compliance, and controversy management into a unified approach that can help anticipate risk, leverage available relief, and reduce unnecessary tax exposure.
Employee & Executive Fringe Benefits
Fuller Tax Law Group partners with senior tax, legal, and HR leadership to design and implement compliant, tax-efficient noncash benefit structures across executive and workforce populations. Our approach seeks to align with workforce strategy, reinforce talent retention objectives, and satisfy regulatory requirements while preserving operational flexibility.
Our work encompasses accountable plans, employee discounts, de minimis fringes, executive benefits (including security arrangements, spousal travel, and personal use of corporate aircraft), educational and adoption assistance programs, supplemental unemployment benefit plans, wage recharacterization strategies, disaster relief programs, and other noncash employee fringe benefits frequently examined as part of broader IRS employment tax audits. In the area of executive security arrangements, we work closely with both your tax team and your third-party security providers to ensure the required security studies appropriately reflect genuine security needs while also conforming to the associated tax considerations. The primary objective of these studies and their required periodic reviews must remain the protection of senior executives; tax considerations should support—not distort—that mission. [Use twice?]
Fuller Tax Law Group works to optimize tax efficiency while preserving competitive benefit offerings that support retention and workforce stability. Recently, we assisted a multinational employer in redesigning one of its most valued employee fringe benefit programs serving more than 25,000 employees. The objective of this C-suite initiative was to enhance the benefit offering while significantly strengthening its compliance framework.
We strive to align technical tax compliance with HR strategy to achieve and maintain competitive offerings while minimizing payroll tax exposure.
Worker Classification & Contingent Workforce Compliance
Fuller Tax Law Group counsels employers on structuring and defending contingent workforce models in an IRS enforcement environment where full-rate federal reclassification assessments can exceed 30% of the total payments made to those affected workers. Through proactive planning and strategic use of available relief provisions, federal payroll tax reclassification exposure can often be materially reduced—or, in appropriate cases, eliminated altogether depending on specific facts and circumstances.
In one such audit during prior private practice, the IRS proposed a multi-million-dollar reclassification adjustment supported by substantial factual development. After being brought in to assist with the audit, the matter was resolved for less than $25,000 through deep understanding and careful leveraging of two different relief strategies to the employer’s specific facts.
Experience has taught us that navigating complex tax rules often requires such disciplined strategy. Yet in appropriate circumstances, the most effective path forward is not a cautious, step-by-step negotiation through the regulatory maze, but the direct assertion of a well-supported position grounded firmly in the law—one that moves decisively past the regulatory maze’s many turns, dead ends, and other obstacles.
We pursue scalable workforce frameworks that preserve operational flexibility and competitive positioning while mitigating reclassification and payroll tax audit risk—without requiring disruptive workforce redesign.
Payroll Tax Compliance
Fuller Tax Law Group counsels employers on structuring and defending contingent workforce models in an IRS enforcement environment where full-rate federal reclassification assessments can exceed 30% of the total payments made to those affected workers. Through proactive planning and strategic use of available relief provisions, federal payroll tax reclassification exposure can often be materially reduced—or, in appropriate cases, eliminated altogether depending on specific facts and circumstances.
In one such audit during prior private practice, the IRS proposed a multi-million-dollar reclassification adjustment supported by substantial factual development. After being brought in to assist with the audit, the matter was resolved for less than $25,000 through deep understanding and careful leveraging of two different relief strategies to the employer’s specific facts.
Experience has taught us that navigating complex tax rules often requires such disciplined strategy. Yet in appropriate circumstances, the most effective path forward is not a cautious, step-by-step negotiation through the regulatory maze, but the direct assertion of a well-supported position grounded firmly in the law—one that moves decisively past the regulatory maze’s many turns, dead ends, and other obstacles. [BOX?]
We pursue scalable workforce frameworks that preserve operational flexibility and competitive positioning while mitigating reclassification and payroll tax audit risk—without requiring disruptive workforce redesign.
Tax Controversy & IRS Audit Defense
Our three core practice areas are supported by integrated controversy and audit defense when issues arise. This operational structure parallels the “field service” structure utilized by the IRS National Office. As such, Fuller Tax Law Group personnel have extensive backgrounds involving complex IRS examinations, IRS Appeals, and, when necessary, litigation addressing fringe benefit, worker classification, and payroll tax matters. Tax controversies encompassing these areas often carry material financial exposure, particularly audits targeting employment taxes and independent contractors.
We manage information flow strategically, position issues early, and pursue well-supported resolutions through no-change letters, negotiated settlements, and leveraged statutory relief programs.
Our objective extends beyond dispute resolution—we actively strive to enhance your eligibility for statutory and administrative relief provisions that reduce future audit exposure and strengthen long-term employment tax governance.
Emerging & Renewed IRS Enforcement Priorities & Initiatives
While Fuller Tax Law Group is anchored in the three specialized disciplines of employee fringe benefits, contingent workforce compliance, and federal payroll taxes, certain issues associated with these three specialized areas can command heightened attention due to IRS enforcement initiatives, major regulatory developments, and sustained public scrutiny. When such matters intersect with our core practice areas, we approach them not as passing market opportunities, but as material components of the broader employment tax risk framework facing large employers.
Unlike providers who may pursue temporary visibility driven by headlines or enforcement cycles, our engagement reflects enduring subject-matter depth rooted in our high-impact service areas. We evaluate high-profile issues within the full compliance and governance landscape — ensuring that guidance on emerging matters is measured, well-supported, and aligned with your long-term tax and financial objectives.
Two areas that currently warrant such additional attention are the personal use of corporate aircraft and the Employee Retention Tax Credit (ERC or ERTC).
Personal Use of Corporate Jets
The personal use of employer-provided aircraft has become an area of heightened IRS enforcement and public scrutiny. Recent IRS examinations of this valuable executive benefit often evaluate the classification of flights as business, personal, or entertainment—including commuting flights (and related tax-home determinations), spousal travel, and travel undertaken for bona fide security purposes. These classifications directly affect payroll tax reporting for both the employer and the executives involved and may also influence the employer’s deduction treatment for aircraft operating expenses.
The governing tax rules are highly technical and require careful coordination across compensation reporting, valuation methodologies, and substantiation requirements. Personal use generally results in imputed compensation that must be reported as taxable wages for payroll tax purposes, typically calculated under the applicable SIFL valuation rules rather than charter value. IRS examinations in this area frequently focus on flight logs, valuation calculations, and documentation supporting the business purpose of each flight. Addressing these rules requires alignment among tax, payroll, finance, and executive compensation teams so that aircraft usage policies, reporting procedures, documentation practices, and internal controls remain consistent.
Fuller Tax Law Group advises large employers on structuring and updating aircraft usage policies, evaluating the tax treatment of executive travel—including spousal travel and travel undertaken for bona fide security purposes—and implementing defensible compliance frameworks designed to withstand IRS examination. Our work includes analyzing SIFL valuation, coordinating payroll tax reporting, assessing the classification of flights across business, personal, and entertainment use, and assisting with IRS audits. We also evaluate statutory, regulatory, and administrative relief provisions that may mitigate potential exposure for both the employer and its executives. This area continues to receive sustained attention in IRS examinations of large employers.
In one such audit during prior private practice, the IRS proposed a multi-million-dollar reclassification adjustment supported by substantial factual development. After being brought in to assist with the audit, the matter was resolved for less than $25,000 through deep understanding and careful leveraging of two different relief strategies to the employer’s specific facts.
Experience has taught us that navigating complex tax rules often requires such disciplined strategy. Yet in appropriate circumstances, the most effective path forward is not a cautious, step-by-step negotiation through the regulatory maze, but the direct assertion of a well-supported position grounded firmly in the law—one that moves decisively past the regulatory maze’s many turns, dead ends, and other obstacles. [BOX?]
We pursue scalable workforce frameworks that preserve operational flexibility and competitive positioning while mitigating reclassification and payroll tax audit risk—without requiring disruptive workforce redesign.
Employee Retention Credit (ERC) Counsel
Fuller Tax Law Group advises sophisticated employers on the Employee Retention Credit within a heightened enforcement environment, ensuring claims are lawful, well-supported, and sustainable. Our work spans legacy claims, active IRS examinations, and strategic repayment or mitigation planning where appropriate.
The Fuller Tax Law Group team includes the senior IRS executive who, in addition to being the agency’s senior authority on many employee fringe benefit and payroll tax issues, led the IRS’s ERC guidance and implementation initiatives prior to leaving government service.
Our services include rigorous eligibility analysis, development of durable documentation frameworks, extended statute and erroneous refund risk assessments, and audit-ready preparation. We also assist with voluntary correction of overstated claims and defense of erroneous refund audits, including extended statute of limitations exposure.
Our objective is straightforward: secure legitimate credits while containing financial and reputational risk and preserving long-term compliance integrity.