Trusted by Large Employers to Navigate
the Most Complex Tax Challenges
Fortune 500 companies and other large employers rely on Fuller Tax Law Group when the stakes are high and concentrated experience is essential to address complex matters involving executive and employee fringe benefits, worker classification, and federal payroll taxes.
Unlike national and international firms that understandably diffuse their tax practices across broad disciplines, we concentrate exclusively on these high-impact areas. That singular focus enables us to develop deep technical fluency and deliver positions intended to achieve business-aligned objectives, withstand IRS scrutiny, and enhance tax-favored outcomes.
Our perspective is further informed by prior senior leadership within the IRS National Office. During their tenure, our attorneys helped shape key enforcement initiatives and administrative relief provisions—many of which remain in force today. That firsthand experience generates uncommon insights into how the IRS sets priorities, conducts examinations, and resolves complex matters involving these areas—IRS insights few, if any, other law firms can credibly match.
For example, when a Fortune 500 tax department conducted a national search for concentrated expertise involving a critical fringe benefit and related federal payroll tax compliance issue, only three attorneys were identified as possessing the requisite depth of experience. Fuller Tax Law Group was retained—our team includes two of those attorneys.
Focused Experience. Proven Results. Practical Counsel.
→ Exclusive Focus:We do not diffuse our practice across unrelated tax disciplines. Fuller Tax Law Group deliberately concentrates on noncash fringe benefits, worker classification risks, and federal payroll taxes—supported by coordinated audit defense strategies across all three areas.
→ Deep IRS Insight: Our attorneys were directly involved in shaping various regulations, rulings, and administrative positions that the IRS continues to enforce in these three specialized practice areas. Few, if any, other law firms have this same depth and breadth of IRS National Office experience and insight in these three areas — reflecting a sophisticated understanding of regulatory intent, IRS positions, and enforcement leverage points.
→ Proactive Risk Management: Fuller Tax Law Group advises employers on strategies intended to reduce audit exposure, to recover tax overpayments, and to develop workforce and compensation models built to withstand regulatory scrutiny.
→ Business-Aligned Execution: Our counsel integrates technical experience with operational realities—we seek to protect your tax positions while preserving flexibility and maintaining strategic control over compensation structures that directly affect both employer and employee tax outcomes.
Why Choose The Fuller Tax Law Group
What Sets Us Apart
What We Deliver
Why It Can Matter
IRS National
Office Insights
Senior-level experience shaping IRS guidance, enhanced by Am Law 100 partner experience
Informed perspective on how IRS interprets, prioritizes, and enforces rules
Three Core
Practice Areas
Focused practice in key areas of payroll taxes, fringe benefits, and worker classification
Precision in high-risk areas aligned with core IRS enforcement priorities
Boutique Precision, National Depth
Direct access to senior counsel combining IRS National Office and Am Law 100 experience
Combines responsiveness with sophistication expected by large employers
IRS Relief
Provisions
Strategic integration of little-known relief strategies into planning and defense practices
Reduces exposure while strengthening overall compliance posture
Enterprise-Level Experience
Experience advising Fortune 500 companies/federal agencies—informed by IRS National Office experience
Solutions calibrated to enterprise scale, complexity, and operational realities
Proactive Risk Management
Forward-looking compliance reviews and planning grounded in IRS enforcement priorities
Anticipates issues, enhances audit readiness and leverages relief programs
Audit Defense & Controversy
Comprehensive end-to-end representation in IRS Exams and Appeals, litigation rarely required
Protects enterprise value during high-stakes IRS audits and regulatory scrutiny
Fringe Benefit Structuring
Design of tax-efficient fringe benefit programs incorporating available IRS relief provisions
Balances FICA and income tax efficiency with competitive workforce offerings
Contingent Workforce Structuring
Development of contractor and workforce models aligned with regulatory frameworks and relief provisions
Mitigates costly FICA and FITW risks while supporting business flexibility
Business-Aligned Counsel
Measured, supportable positions grounded in statute, regulation, and administrative practice
Supports financial reporting integrity and reputational risk management objectives
Comprehensive Support for Complex Compliance Challenges
From strategic tax planning and compliance reviews to IRS examinations, IRS Appeals, and litigation, we partner with large employers and their existing legal teams to pursue tax-favored compliance outcomes aligned with enterprise objectives. Our comprehensive support is designed to:
→ Structure compliant fringe benefit and contingent workforce models
→ Reduce audit exposure and contain tax liabilities
→ Defend high-stakes fringe benefit, worker classification, and payroll tax positions
→Recover overpayments and secure penalty relief
Protecting Your Business. Strengthening Your Workforce. Delivering Sustainable Compliance.
At Fuller Tax Law Group, we provide concentrated focus informed by leadership experience inside the IRS and in leading national law firms. As trusted counsel to large employers, we help structure and preserve compliant, competitive workforce and compensation strategies intended to withstand scrutiny and support long-term business objectives.
