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Photo of Courtney A. Hopley

Courtney A. Hopley represents clients in federal and state tax controversies before the IRS and the California Franchise Tax Board at the audit, collection, appeals and litigation stages. She works on tax controversy matters involving partnerships, corporations, individuals, real estate and penalty disputes. Courtney also has experience in tax planning involving entity formation, mergers and acquisitions, and reorganization transactions.

On August 10, 2020, the San Francisco Superior Court granted the State of California a preliminary injunction requiring Uber and Lyft to reclassify their drivers as employees.  People of the


Continue Reading Court Rules that Uber and Lyft Cannot Treat California Drivers as Independent Contractors

In July 2019 the IRS identified post offshore voluntary disclosure program (OVDP) compliance as a campaign. The purpose of the campaign is to pursue those OVDP participants who fail to
Continue Reading Your Offshore Voluntary Disclosure May Be Long Over but the IRS May Be Looking at Your Ongoing Tax Compliance

On Nov. 29, 2018, the IRS released a memorandum with new procedures for all voluntary disclosures following the end of the Offshore Voluntary Disclosure Program (OVDP) on Sept. 28, 2018.
Continue Reading IRS Releases New Voluntary Disclosure Procedures for Post 9-28-2018 Offshore and Domestic Disclosures

The IRS announced that it will end the Offshore Voluntary Disclosure Program (OVDP), effective September 28, 2018.  The IRS is pressing taxpayers with undisclosed foreign accounts, entities and income to
Continue Reading IRS Announces it Will End the Offshore Voluntary Disclosure Program Effective September 28, 2018