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Meadows, Collier, Reed, Cousins, Crouch & Ungerman, L.L.P.

901 Main Street, Suite 3700
Dallas, TX 75202

Phone: 214.744.3700
Fax: 214.747.3732
Toll Free: 800.451.0093

submit inquiry
Josh O. Ungerman

Mr. Ungerman’s experience as a former IRS Senior Trial Attorney and Department of Justice (DOJ) Special Assistant U.S. Attorney are invaluable in helping clients with estate planning and family wealth transfers along with IRS civil tax and criminal tax controversy matters at all levels. The tax and estate matters in which Josh is involved are typically very complex from both a factual and legal perspective. These matters often require legal and accounting skills. Josh is also a Certified Public Accountant.

Josh works with the families on wealth preservation and transfer strategies. A major focus is on accomplishing family wealth preservation goals with an emphasis on the efficient transfer of family wealth to the next generation from a business and tax perspective.

He is also involved in defending Taxpayers & issues against IRS inquiries and actions. The IRS defense practice covers Civil and Criminal Exams, Investigations and Trials. Many of Josh’s Tax Controversy matters include an offshore component.

Mr. Ungerman is often selected to many “Best of” attorney lists by his peers including: Best Lawyers, D Magazine and Texas Monthly.  He was selected to the Texas Super Lawyers Top 100 Lawyers in Texas list.

Prior to joining the firm in 1994, he was a civil prosecutor for the Internal Revenue Service, Dallas District Counsel office. He was also a Special Assistant United States Attorney for the Department of Justice in Dallas during his time as a civil prosecutor.  Prior to becoming an IRS attorney of a special assistant U.S. attorney, he served as a law clerk to the Honorable Carolyn M. Parr at the United States Tax Court in Washington, D.C. 

Josh is a frequent speaker on tax topics including exams, IRS estate tax strategies, tax shelter defense, recent tax legislation, IRS criminal tax investigation techniques, and state tax controversy issues.

Mr. Ungerman was admitted to practice in Texas in 1990.

  • Southern Methodist University School of Law, J.D., 1990
    • Board of Editors, Southwestern Law Journal
  • University of Texas at Austin, B.B.A., 1987
  • Dallas Bar Association
    • Past Chair, Tax Section
  • State Bar of Texas
    • Past Chair, Tax Controversy Committee
  • American College of Tax Counsel
    • Fellow
  • American Bar Association
    • Member, Appointments to the Tax Court Committee, Tax Section, 2015-2017
    • Past Chair, Civil and Criminal Tax Penalties Committee, Tax Section
    • Past Chair, IRS Investigations and Practices Subcommittee, Tax Section on Civil and Criminal Tax Penalties
  • American Institute of Certified Public Accountants
  • Texas Society of Certified Public Accountants
  • Dallas CPA Society
    • Tax Committee
  • New York University School of Continuing and Professional Studies
    • Planning Committee Member, 2nd Annual Tax Controversy Forum
  • UCLA Extension, Business, Management, and Legal Programs
  • Planning Committee Member, 25th Annual Tax Controversy Institute
  • Texas Super Lawyers-Tax as listed in Texas Super Lawyers Magazine and Texas Monthly, 2003 through 2017
  • Texas Super Lawyers, Top 100 Lawyers in Texas list, 2017
  • The Best Lawyers in America©, 2015, Tax Law 
  • 2013 Top Rated Lawyer in White Collar Criminal Defense Law by ALM as published in The American Lawyer, Corporate Counsel & The National Law Journal, October 2013
  • Best Lawyers in Dallas, D Magazine, 2008 and 2011; Taxation: 2012, 2015 and 2016: Tax Litigation
  • Best Business Lawyers, D Magazine, 2009: Tax 
  • Best Lawyer Under 40, D Magazine, 2004 and 2005
  • Congratulations to Josh Ungerman for his five-year appointment to the American Bar Association Section of Taxation’s Committee on Appointments to the Tax Court ending June 30, 2023.

Prior Experience

  • Civil Prosecutor, Internal Revenue Service, Dallas District Counsel office
  • Special Assistant United States Attorney, Department of Justice, Dallas
  • Law Clerk, Honorable Carolyn M. Parr, United States Tax Court, Washington, D.C.
  • He published an article in the April 2016 issue (Volume 41, Number 4) in the Dallas Bar Association Headnotes on, "Summer Vacation in the Caribbean - Not so Fast."   
  • Mr. Ungerman published an article in the Fall 2014 issue of the Texas Tax Lawyer on "Are Virtual Currencies Such as Bitcoin the Next Tool for Tax Evaders - The IRS is Watching and You Might Be Surprised What They See. “TEFRA Partnership IRS Controversies: Now That The TEFRA Partnership Exam Is Complete With An FPPA, What Is A Partnership To Do?", Forbes IRS Watch, July 22, 2013.
  • He published an article, "A Practical Guide to the New Round of IRS Examinations" in the Fall/Winter 2012, (Volume 31, No. 3) of the Petroleum Accounting and Financial Management Journal published by the Institute of Petroleum Accounting at the University of North Texas.
  • Alan K. Davis and Josh O. Ungerman published an article, "An Untaxing Year" in the December 20, 2010 Texas Lawyer, Vol. 26., No. 38.
  • "Proposed Schedule Targets Uncertain Tax Positions", In-House Texas, (An ALM Publication), Volume 25, No. 48, March 1, 2010.
  • "Government Loses Sham-Transaction Criminal Tax Case in the Virgin Islands", The American Bar Association, Criminal Justice Section Newsletter, Volume 17, Issue 3, Spring 2009.
  • “The IRS is Regularly Auditing Taxpayers Again", Dallas Bar Association Headnotes, Volume 32, Number 11, November 1, 2008.
  • “The IRS Is Looking For Non-Compliant Taxpayers With Foreign Interests: Is Your Taxpayer One Of Them?”, The Practical Tax Lawyer, Volume 22, Number 3, Spring 2008 (published four times a year by American Law Institute-American Bar Association Continuing Professional Education in cooperation with the ABA Section of Taxation).
  • “Important Tax Controversy Developments”, Texas Tax Lawyer.
  • “Voluntary Disclosure and IRS Attacks on Offshore Credit Cards”, Corporate Business Taxation Monthly.
  • “When IRS Criminal Special Agents Show up at Your Client's Door", Dallas Bar Association Headnotes, Volume 29, Number 2, March 1, 2005.
  • “Foreign Distrust: Cayman Island Crackdown Reveals IRS Concern”, Texas Lawyer
  • “Texas Sales Taxes on Construction-Why Can’t Anybody Get It Right?”, Texas Tax Lawyer.
Quotes:
  • Mr. Ungerman is quoted in a BNA Daily Tax Report article on January 16, 2014 titled, "Julius Baer Decision Offers Little Safety For Hidden Swiss Accounts, Attorneys Say" by Alison Bennett and Daniel Pruzin and December 20, 2013 titled, "Swiss Banks Under Pressure as Deadline Nears for DOJ Program to Find U.S. Accounts" by Alison Bennett. 
  • Mr. Ungerman is quoted in BNA's Daily Tax Report on August 15, 2011 in an article titled, "Taxpayers Fear Disclosing Offshore Assets As Deadline Approaches, Practitioners Say." 
  • He is quoted in an article, "Fairness and Transparency Still Problems for OVDP" by Andrew Velarde in Tax Notes Today in Tax Analysts, January 15, 2015.
  • Mr. Ungerman is quoted in "Second Circuit Reverses Convictions of 2 Former E&Y Shelter Promoters" in Tax Notes by Tax Analysts, November 30, 2012.
  • He is quoted in "The IRS's Misguided Fraud Whodunit" by Jeremiah Coder in Tax Notes by Tax Analysts, October 1, 2012.
  • He is quoted in "Applying Mayo, Federal Circuit Defers to Controversial Overstated Basis Regulation, by Jeremiah Coder in Tax Notes by Tax Analysts, March 14, 2011.
  • Mr. Ungerman is quoted in the article, "Seventh Circuit Overturns Tax Court on Gross Income Omission" by Jeremiah Coder in Tax Notes by Tax Analysts, January 31, 2011.
  • Josh O. Ungerman is quoted in an article, "Hackers Offering Romney's Tax Returns Face Serious Punishment if Caught" by William Hoffman in the Daily Tax Report , September 7, 2012.
  • He is quoted in "IRS Withdraws 'John Doe' Summons Against UBS Over Tax Fraud Allegations" by Daniel Pruzin (Geneva) and Alison Bennett (Washington) in the Daily Tax Report, November 17, 2010.
  • Mr. Ungerman is quoted in a Tax Practice article published by TaxAnalysts on May 24, 2010 "IRS Undeterred After Tax Court's Intermountain Decision."
  • He is quoted in a Tax Practice article published by TaxAnalysts on April 12, 2010, "IRS Help for Struggling Taxpayers Contrasts With Enforcement Push"
  • Mr. Ungerman is quoted in a Tax Practice article published by TaxAnalysts on April 5, 2010, "Federal Circuit Overturns Penalty Determination in Jade Trading.”   
  • Mr. Ungerman is also quoted in an article published on taxanalyst.com entitled, "Swiss Agree to Expedite Processing of 4,450 UBS Accounts Under Treaty Request" by David D. Stewart on August 20, 2009. 
  • He was also quoted in an article on bloomberg.com entitled, "Billionaire Tax Felon Says UBS Lied in Pledge to Report to IRS" by David Voreacos on June 9, 2009. 
  • Another article he was quoted in was published on moneylaundering.com entitled, "Uptick in Tax Evasion Disclosures Mean More Bank Investigations, Say Attorneys" by Matt Squire on November 5, 2008. 
  • Mr. Ungerman is quoted in the book, “The Cheating of America: How Tax Avoidance and Evasion by the Super Rich Are Costing the Country Billions–and What You Can Do About It" by Charles Lewis and Bill Allison and the Center for Public Integrity.
June 22, 2018

10th Annual NYU Tax Controversy Forum... [ read ]

December 7, 2017

ABA 34th Annual National Institute on Criminal Tax Fraud... [ read ]

October 23, 2017

Hein & Associates National Tax Meeting... [ read ]

September 18, 2017

PLI's Basics of International Tax - September 18, 2017 in San Francisco, CA... [ read ]

July 26, 2107

AXA Advisors Seminar... [ read ]

July 26, 2017

2017 IRS Nationwide Tax Forums Seminar... [ read ]

July 18, 2017

PLI's Basics of International Tax - July 18, 2017 in New York... [ read ]

June 15, 2017

NYU Tax Controversy Forum... [ read ]

June 6, 2017

Tax Alliance Conference... [ read ]

May 23, 2017

Texas Bank and Trust Seminar... [ read ]

May 9, 2017

Texas Bank and Trust Seminar... [ read ]

May 4, 2017

Texas Association of CPAs... [ read ]

May 1, 2017

East Texas Chapter/TSCPA Spring CE Expo... [ read ]

December 8, 2016

33rd Annual National Instit. on Criminal Tax Fraud & the Sixth Annual National Institute on Tax Controversy... [ read ]

November 30, 2016

UT Law 2016 Taxation Conference... [ read ]

November 14, 2016

SMU Dedman School of Law... [ read ]

October 25, 2016

18th Annual Meadows Collier Tax Conference... [ read ]

September 19, 2016

PLI in New York and Califorina... [ read ]

July 19, 2016

PLI in New York and Califorina... [ read ]

June 14, 2016

Tax Alliance Conference... [ read ]

May 18, 2016

Civil and Criminal Employment Tax Enforcement Efforts - Employers Beware Live CLE Webinar & Teleconference... [ read ]

December 11, 2015

32nd Annual Natl Instit on Criminal Tax Fraud & 5th Natl Instit on Tax Controversy... [ read ]

November 3, 2015

2015 Meadows Collier Taxation Conference... [ read ]

June 5, 2015

NYU 7th Annual Tax Controversy Forum... [ read ]

May 19, 2015

Central Texas Chapter/TSCPA CPE Expo- Waco... [ read ]

May 19, 2015

"Surviving an IRS EO Audit"... [ read ]

January 15, 2015

"Circular 230: Oversight of the Tax Practitioner" "Hot Topics in IRS Audits and Investigations"... [ read ]

December 11, 2014

"Ask The Experts: Top Tips in Criminal Tax Cases"... [ read ]

November 7, 2014

"The Eggshell IRS Exam: Tips for Survival and Strategies for Success"... [ read ]

October 20, 2014

"The Eggshell IRS Exam: What to Do?"... [ read ]

August 28, 2014

"Foreign Asset Reporting Obligations to the IRS"... [ read ]

June 20, 2014

"IRS Small Business/Self-Employed Division Update"... [ read ]

May 22, 2014

"Passive Activity and Hobby Loss Limitations: Withstanding an IRS Attack of Your Client's Outside Business Activities Under Sections 469 & 183"... [ read ]

April 23, 2014

"Fraud, Omissions, Errors and Missed Deadlines"... [ read ]

December 12, 2013

"Prosecution and Defense of a Klein Conspiracy"... [ read ]

December 10, 2013

"Business Owner/Individual Estate Planning"... [ read ]

November 19, 2013

"Civil and Criminal Penalty and Eggshell Audits"... [ read ]

November 6, 2013

"Trust Fund Recovery Penalty"... [ read ]

June 19, 2013

"Statutes of Limitations, Assessments, Abatements, and Claims for Refund"... [ read ]

June 12, 2013

"How to Manage Criminal Cases When CI Knocks on Taxpayer's Door"... [ read ]

June 7, 2013

"Criminal Investigation Division Update"... [ read ]

May 29, 2013

"What We Can Expect from the IRS in 2013"... [ read ]

May 8, 2013

"Panelists - Criminal Tax"... [ read ]

November 5-7, 2012

Speech Title TBA... [ read ]

October 17, 2012

"Judgment Day: Preparing for a Visit from Uncle Sam"... [ read ]

September 21, 2012

"Managing IRS Audits"... [ read ]

August 28, 2012

"Estate Planning for Business Owners"... [ read ]

July 20, 2012

"Judgment Day: Preparing for a Visit from Uncle Sam"... [ read ]

June 8, 2012

"Home Concrete, Mayo, and other TEFRA Substance"... [ read ]

May 17, 2012

"Compliance Issues for U.S. Partnerships with Foreign Partners and U.S. Partners with Foreign Partnerships"... [ read ]

May 16, 2012

"Judgment Day: Preparing for a Visit from Uncle Sam"... [ read ]

May 8, 2012

"Making Ends Meet: Getting Paid Consistently and Ethically"... [ read ]

May 2, 2012

"Making Ends Meet: Getting Paid Consistently and Ethically"... [ read ]

February 9, 2012

"Uncle Sam is More Active Than Ever: IRS Exam and Collection... [ read ]

January 4, 2012

"Preparing for and Defending the Examination of Estate and Gift Tax Returns"... [ read ]

December 1, 2011

"The IRS "Wealth Squad": If You Don't See Them in LB&I; Get Ready for their Influence on SBSE"... [ read ]

November 17-18, 2011

"Recent Developments in Texas Taxation"... [ read ]

November 14, 2011

"Practical Suggestions and Traps to Avoid When Working with the IRS"... [ read ]

November 3, 2011

"Judgment Day: Preparing for a Visit from Uncle Sam"... [ read ]

October 22, 2011

"Get Ready for the Newest Specialized IRS Civil Agents: The SBSE Fraud/Bank Secrecy Act/Anti-Money Laundering Agent" (Moderator)... [ read ]

September 30, 2011

"Preparing for and Defending the Examination of Estate and Gift Tax Returns"... [ read ]

August 24, 2011

"How CPAs Get in Trouble with the IRS"... [ read ]

July 26-28, 2011

"Examination Representation 101" "Reporting Cash Transaction and Foreign Financial Accounts (FBAR)"... [ read ]

May 18, 2011

"Don't Give Up on Family Limited Partnerships (FLPs)" "Differences Between Aggressive Tax Planning and Tax Fraud" "The Legislative and Admi... [ read ]

May 4, 2011

"Don't Give Up on Family Limited Partnerships (FLPs)" "Differences Between Aggressive Tax Planning and Tax Fraud" "The Legislative and Administrat... [ read ]

March 2, 2011

"Evolution of an IRS Fraud Case"... [ read ]

December 9, 2010

"What is the IRS Doing to Us Next?"... [ read ]

December 6, 2010

"What is the IRS Doing to Us Next?"... [ read ]

December 2, 2010

"Hot Issues and Priorities in IRS Examination and Appeals" "What is the IRS Doing to Us Next?"... [ read ]

November 4-5, 2010

"Federal income Tax Update--Planning in an Uncertain Climate" "Estate Planning Update and Year-End Planning" "Evolution of an IRS Fraud Case"... [ read ]

November 1, 2010

"IRS Hot Topics, The 2010 HIRE ACT, Examination of Estate and Gift Tax Returns, Keeping Estate Planners Out of Trouble and The Evolution of an IRS Fraud Case"... [ read ]

October 15, 2010

"Preparing for and Defending the Examination of Estate and Gift Tax Returns"... [ read ]

October 6, 2010

"Keeping Estate Planners Out of Trouble"... [ read ]

September 25, 2010

"Civil Tax Penalty Abatements - Fact or Fiction"... [ read ]

May 26, 2010

"Transfer Tax Litigation and the Keller Decision" "No Estate Tax - Now What?" "Evolution of an IRS Fraud Case"- Longview... [ read ]

May 20, 2010

"Differences Between Aggressive Tax Planning and Tax Fraud"... [ read ]

May 12, 2010

"Transfer Tax Litigation and the Keller Decision" "No Estate Tax - Now What?" "Evolution of an IRS Fraud Case"- Tyler... [ read ]

February 23, 2010

"Preparing for and Defending the Examination of Estate and Gift Tax Returns"... [ read ]

January 23, 2010

"The IRS Wealth Squad - Holistic Taxpayer Analysis"... [ read ]

November 3, 2009

"The IRS is Engaging Taxpayers Again: From Examination to Investigation-What the IRS is Looking For and How to Respond"... [ read ]

October 21, 2009

"Liability and Disclosure Issues/Circular 230 and Code 7216"... [ read ]

October 01, 2009

"Preparing for and Defending the Examination of Estate and Gift Tax Returns"... [ read ]

September 26, 2009

"Trial Strategies in Complex Tax Prosecutions: Evidentiary and Procedural Challenges" and "Practical Considerations Involving Ongoing Voluntary Disclosures (of Offshore Accounts)"... [ read ]

September 9, 2009

"Circular 230: Best Practices"- Dallas... [ read ]

September 8, 2009

"Circular 230: Best Practices"- Dallas... [ read ]

July 6, 2009

"Sink or Swim: IRS Throws Out a Limited-Time Voluntary Disclosure Program as a Life Preserver to Taxpayers Treading in Shark-Infested International Waters"... [ read ]

May 27, 2009

Annual Taxation and Estate Planning Update for Professionals Seminar sponsored by Texas Bank and Trust- Tyler... [ read ]

May 20, 2009

Annual Taxation and Estate Planning Update for Professionals Seminar sponsored by Texas Bank and Trust- Longview... [ read ]

April 10, 2017

IRS Criminal Investigation Is Still Active Despite Fewer Investigations - Ask Caterpillar... [ read ]

IRS Criminal Investigation (CI) recently released their 2016 Annual Report. The report tries to put the best face on the continually diminishing number of investigations. From 2013 through 2016, the number of investigations initiated by IRS CI has dropped an amazing 36%. During that same time period, the number of IRS Special Agents has dropped almost 13%.

March 31, 2016

IRS Commissioner Makes Shocking Admission on the Effects of Congressional Budget Cutbacks - the IRS Will Lose $5 Billion in Tax Revenue Per Year... [ read ]

The IRS called the complicated tax plans offered by international accounting and law firms to their wealthy clients in the late 1990s and early 2000s "tax shelters". The IRS shut down that type of planning through aggressive enforcement and a revamping of the requirements for written tax advice. Since those "tax shelters" are long gone, it is disturbing that in March of 2016, IRS Commissioner Koskinen has admitted defeat to a $5 billion a year tax revenue loss.

January 7, 2016

IRS Criminal Employment Tax Enforcement: The Next Big Thing... [ read ]

The IRS has experienced a 28% decline in collectors from 2010 to 2014. Meanwhile, the IRS estimates that $59 billion is owed from unpaid employment taxes from which employment tax returns have been filed. Additionally, taxes withheld by employers make up two-thirds of IRS revenue collection by the IRS. These factors converge for the perfect storm of IRS Criminal Tax Enforcement on payroll taxes.

January 6, 2016

Spring Break in Mexico -- Think Again if you Owe the IRS... [ read ]

Was the Grinch in Congress last winter? The FAST Act, 2015 Fixing America's Surface Transportation Act, did much more than fix our nation's highways when enacted on December 5, 2015. The FAST Act broke down previous prohibitions that prevented the IRS from sharing information with the State Department.

October 21, 2015

IRS Announces it Has Raised $8 Billion Through its Offshore Remediation Programs While Conducting Thousands of Civil Offshore Exams and Numerous Criminal Offshore Investigations... [ read ]

On Oct. 16, 2015, the IRS announced that its offshore compliance programs have generated $8 Billion in IR-2015-116. More than 54,000 taxpayers have participated in IRS offshore remediation disclosure programs since 2009. The IRS warned taxpayers with non-compliant offshore accounts to "strongly consider existing paths established to come into full compliance with their federal tax obligations."

June 9, 2015

IRS and DOJ representatives made presentations at the NYU's Tax Controversy Forum in New York... [ read ]

On June 5th, a number of IRS and DOJ representatives made presentations at the NYU's Tax Controversy Forum in New York. The following were of interest.

June 4, 2015

How To Identify, Prepare For And Succeed In An IRS Eggshell Examination... [ read ]

Any IRS exam can be nerve-wracking experience for a tax advisor. If there is a large mistake or pattern of mistakes, an ordinary exam may become an eggshell exam requiring much thought and skill to come through the exam unscathed. This article will address the IRS exam areas that lead to IRS eggshell exams, the IRS tactics and, finally, steps a tax advisor can take to minimize the negative consequences.