Tackling Explainability and Interpretability in Language Models
The very nature of language models—large language models (LLMs), foundation models, and frontier models—confounds the notions of explainability and transparency.
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Tax Strategy You Can Trust. Insight You Can Act On.
alliantNational delivers strategic tax and legislative insight. Our team empowers businesses to grow through domestic and international tax planning and providing expert guidance and representation with federal as well as state taxing authorities.
Tax Planning: Compliance and optimization, hand in hand.
Our professionals are thoroughly familiar with the latest developments and tax-reduction strategies, ensuring you stay compliant while capitalizing on every available opportunity. Trust us to navigate the complexities so you can focus on what matters most.
Our Services:
Mergers and Acquisitions
Entity Formation and Dissolution
Domestic and Cross-Border Tax Structuring and Optimization
International Tax
Tax-Exempt and Private Foundations
State and Local Tax
Tax Controversy & Defense
Expert Tax Controversy Management Services: Protect your reputation, safeguard your finances, and gain the certainty you need. We turn potential controversy into control.
Our Services:
- Federal and State Audit Representation
- Administrative Appeals
- Federal and State Debt Collection and Defense
- Litigation Support and Expert Witness Services
- Penalty Abatement
Strategic Tax Services
Expert Tax Strategy: Align your personal and business goals by capitalizing on tax incentives and other initiatives to improve after-tax returns.
Our Services:
- Federal and International Tax Compliance and Review
- Regulatory Affairs and Tax Policy
- General Tax Counsel
- Partnership Tax Services
- Digital Asset Compliance and Review
- Accounting Method Services
- Credits and Incentives
- Green Energy Investment Tax Credits
- Research- National Tax Help Desk
case studies
TAX-EXEMPT ENTITY
Retained Tax-Exempt Status
Our team successfully navigated an audit for a tax-exempt entity facing Form 990 scrutiny and possible loss of its tax-exempt status. We secured a no-change result for the client’s Form 990, ensuring the client retained their tax-exempt status.
Cayman-Based Corporation
U.S. Operations Structuring with International Tax Planning
Assisted a Cayman-based client in structuring U.S. operations through international tax planning to minimize triggering a U.S. trade or business. We developed cross-border tax strategies and helped draft intercompany agreements between U.S. and Cayman entities to minimize U.S. withholding tax exposure while optimizing the overall international tax structure.
INTERNATIONAL CLIENT
$1.5M Withholding Tax Savings
Assisted an inbound client with cross-border transactions involving sourcing and tax treaty opinion work. The comprehensive analysis and strategic planning resulted in $1.5 million in savings for our client in U.S. withholding taxes.
Large Business Enterprise
$1M+ Trust Fund Recovery Penalty Appeal
Our team prevailed in a Trust Fund Recovery Penalty Appeal involving more than $1 million in proposed penalties. We leveraged IRS missteps and inadequate development of evidence to secure a full concession for our individual client.
Business Credit Dispute
$785,000 Credit Utilization Resolution
A general business credit was being disallowed by the IRS. Our team determined the IRS was denying the credit based on an erroneous interpretation of the statute and had the determination reversed, securing the full credit amount plus interest for our client.
1042 Examination
$500,000 Tax Addition Eliminated
Represented a client in their 1042 examination after the auditor proposed a $500,000 addition to tax based on defective W-8BEN-E forms. We helped resolve the defective forms by requesting affidavits of unchanged status from international customers, which resulted in the closure of the no-change audit.
Form 5471 Penalties
$800,000+ Penalty Abatement
Successfully abated over $800,000 in penalties assessed by the IRS for failure to file Form 5471, Information Return of U.S. Persons with Respect to Certain Foreign Corporations.
High Wealth Client
$500,000+ Refund From $15m Audit
Represented a client in a global high-wealth audit dealing with international tax issues, including GILTI, foreign tax credits, and withholding tax exposure. Despite the IRS initially claiming $15 million in understated income, we provided comprehensive tax position papers that resulted in the exam team conceding all issues and our client receiving a $500,000+ refund.
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