Is Your Spouse Innocent?
by MARIANNE MAN
Lauren thought she had married the perfect man. She and her husband, Charles, met at UCLA during their first year of college. He swept her off her feet with his intellect and charm, and when he received his acceptance into medical school at UCSF, she followed him. Charles proposed during his last year of his medical residency. Lauren felt her life was complete when, two years after they married, the couple was blessed with a beautiful daughter. Lauren decided to stay at home with her daughter and become a full-time homemaker. She left all financial decisions to her husband, whom she always knew to be trustworthy.
Are You FBAR Serious?
Marianne H. Man
Are you FBAR serious? Seriously, do you know what a FBAR is? If you are a tax attorney or a CPA, you may be well-acquainted with the term, “FBAR”, but for many individuals and owners of businesses, the requirements of the Foreign Bank and Financial Accounts Report (“FBAR”) are foreign concepts. As a result, when the FBAR reporting requirements are explained to them, a common reaction is akin to a dismayed and shocked “Are you FBAR serious?”
Best of Orange County
In OC Metro Magazine for 2013
Ms. Marianne Man is honored to be recognized by OC Metro Magazine as one of the top attorneys for 2013 in OC Metro Magazine’s annual top attorney issue.
Best of Orange County
In OC Metro Magazine for 2014
In 2014, for the second consecutive year, attorney Marianne Man was recognized by OC Metro Magazine as a top attorney in her field of tax law.
Best of Orange County
In Coast Magazine for 2015
For the third consecutive year, attorney Marianne Man of The Tax Counsel, TM has been named one of the “Top Tax Attorneys” in the Orange County, California area. She and her firm, The Tax Counsel,TM is featured in Coast Magazine’s October 2015 issue.
Marianne Dawson-Man
Shareholder, Managing Attorney at Law, Certified Mediator
- Phone: (949) 260-2078
- Email: Marianne@TheTaxCounsel.com
Education and Accreditation
- UCLA (B.A., Economics), Dean's Honor List
- Loyola Law School (J.D. and Tax LL.M. with Distinction)
- Certified Mediator in State of California
- Harvard Law School Executive Education - Mediation and Conflict Management
Expertise/Areas of Practice
- Tax Litigation
- Tax Dispute Resolution
- Representation of Businesses and Individuals before the IRS, CA FTB, CDTFA, CA EDD, and in U.S. Tax Court
- Bankruptcy
- Mediations
- Homeowner Representation in HOA Disputes
- HOA Litigation
- Outside Tax Counsel for Law Firms and Businesses
About Marianne Dawson-Man
Marianne Dawson-Man is an attorney based in Newport Beach, California, specializing in civil and criminal tax dispute resolution and tax litigation, bankruptcy, mediation, and HOA dispute resolution and litigation. She brings over 18 years of experience to her law practice, addressing the needs of entrepreneurs, emerging growth companies, as well as seasoned businesses. She holds a Juris Doctor and an LL.M. in Tax Law from Loyola Law School, Los Angeles, which ranks among the top ten tax law graduate programs in the United States, demonstrating her profound expertise in the tax law field. Additionally, she earned a B.A. in Economics from UCLA, a world-renowned university, ranking as the number 1 public university for 7 consecutive years as of 2024. Her extensive legal background is enriched by her experiences in the U.S. Attorney’s Office – Tax Division, over 15 years at various law firms in areas including estate planning, mergers and acquisitions, succession planning, and tax controversy, as well as her role as a Tax Consultant at a Big Five CPA firm, making her adept in the nuances of tax law across different sectors. Mrs. Dawson-Man is admitted to practice before the U.S. Tax Court, the Supreme Court of the State of California, and the United States Central District Court of California. She was recognized as a “Rising Star” in Mergers & Acquisitions by Los Angeles magazine in its Super Lawyers edition and has been rated as a top attorney by avvo.com since 2013 with an Avvo rating of 10/10 (Superb). She is also a trained, certified mediator in California and studied at Harvard Law School’s Mediation and Conflict Management program for Executive Education. Marianne’s distinguished career is further highlighted by her previous role as the Chair of the Tax Section of the Orange County Bar Association. Her expertise has consistently been acknowledged, earning her accolades as one of the “Top Tax Attorneys” in Orange County by publications such as OC Metro Magazine and Coast Magazine. She actively participates in real estate law as the Secretary/Treasurer of the Orange County Bar Section’s Real Estate Section for 2024, Chair-Elect in 2025, and Chair in 2026.
Practice Areas
Comprehensive Services and Benefits of The Tax Counsel: A Detailed Overview
- No Double Billing and Personalized Service: Unlike many law firms that bring junior associates to client meetings primarily as observers, our firm diverges sharply from the practice of charging clients for these juniors under the guise of active involvement. This often misunderstood form of double billing occurs when firms bill clients for the time junior associates spend in meetings learning the ropes, despite contributing minimally to the actual case. Our approach ensures that only attorneys who directly engage in the management and strategy of your case are involved, guaranteeing that every hour billed is an hour spent working substantively on your case. By reducing our overhead costs and eliminating double billing, we offer a more straightforward and cost-effective billing structure. When comparing legal services, it’s crucial to consider that with other firms, you might need to add the junior associate’s billable rate to the Partner's or Senior Associate's rate to fully understand the actual rate you will be billed at. And, when you hire a tax resolution company that is not a law firm, be sure you understand whether or not you who will actually be working on your case most of the time - a tax attorney or just the non-lawyer staff. By streamlining our practices, we reduce overhead costs and enhance the intimacy and effectiveness of our services. Each client receives consistent, personal attention from the same dedicated attorney throughout the entirety of their case. With every interaction tailored specifically to meet your legal needs, our firm ensures that you receive the best value for your investment, emphasizing clarity, efficiency, and peace of mind throughout your legal journey.
- Attorney-Client Privilege: Tax attorneys offer attorney-client privilege, ensuring that all communications are confidential. Unlike accountants, this privilege is inherent and does not require the direction of a lawyer. This ensures that sensitive information remains protected throughout legal consultations and proceedings.
- Defense in Legal Actions: Tax attorneys are trained to defend clients in legal proceedings against agencies like the IRS, including tax fraud investigations and criminal allegations. Their expertise is critical in navigating the complexities of tax law to provide robust defense strategies that protect client interests.
- Strategic Tax Planning: Firms like The Tax Counsel provide insights into the tax implications of different business entities, and help in reviewing contracts for both legal and tax implications, which is invaluable for transactions such as mergers and acquisitions. Strategic planning can prevent future legal disputes and optimize tax outcomes.
- Preventive Advice: With deep experience in dealing with IRS audits and other tax disputes, tax attorneys like those at The Tax Counsel can offer strategic advice to avoid triggers that lead to audits. This proactive approach helps minimize the risk of costly and time-consuming tax audits.
- Expertise in Specific Jurisdictions: The Tax Counsel™ focuses its law practice on defending clients in IRS and tax matters, and has expertise in dealing with specific tax authorities like the IRS and the California Franchise Tax Board, providing targeted legal assistance to its clients.
- Broad Legal Expertise and Mediation Skills: A tax attorney with knowledge of tax laws, bankruptcy laws, litigation, HOA laws, and certified mediation skills in California can significantly influence the outcome of mediations. Their extensive legal knowledge and mediation expertise ensure effective negotiation and legally sound resolutions, often leading to amicable settlements without the need for lengthy court battles.
- Understanding of Bankruptcy Laws: A tax attorney who is also knowledgeable in bankruptcy laws provides crucial advice on tax liabilities and obligations in bankruptcy proceedings, offering comprehensive solutions for clients with complex financial issues. This expertise is especially valuable when navigating the intersections of tax obligations and debt relief options.
- Exclusive Defense in Homeowners' Association Disputes: The Tax Counsel focuses exclusively on defending homeowners in homeowners' association disputes and HOA litigation, tailoring their legal strategies to advocate effectively for homeowners’ rights and interests. This dedicated focus ensures that homeowners receive specialized representation that is aware of the latest developments and strategies in HOA law.
- Flexible Billing Options: The Tax Counsel offers hourly, flat rate, and subscription-based billing models, allowing clients to choose the option that best suits their financial needs and the nature of their legal matters. This flexibility in billing ensures that legal services are accessible and affordable, adapting to varying financial circumstances and case complexities.
- Collaborative Relationships: Tax attorneys often work closely with CPAs and other lawyers, ensuring a comprehensive approach to handling a client’s financial and legal needs. This collaboration enhances the quality of service, as it combines expertise from various fields to create holistic solutions.
- Potential Conflict of Interest for CPA-Tax Attorneys: While it may initially seem like a good idea to hire CPA-Tax attorneys, professionals who are both certified public accountants and licensed attorneys specializing in tax law, these dually licensed professional can face potential conflicts of interest, especially when defending tax returns that they themselves have prepared before the IRS. Many clients find themselves in situations of conflict of interest due to errors made by their CPA-Tax attorneys, who are responsible for both preparing and defending their tax returns before the IRS. In these scenarios, CPA-Tax attorneys may face a difficult choice between upholding their own professional work and acting in the best interests of their clients. Often, to defend their own preparatory work, they must navigate between prioritizing their professional reputation or financial interests and the legal and financial welfare of their clients. This dual role can compromise the objectivity required for unbiased legal defense, potentially leading to outcomes that do not serve the client's best interests. This inherent conflict is why at our firm, we separate the roles of tax preparation and tax defense by not preparing tax returns for our clients, ensuring that our advocacy is focused solely on the client's needs, free from any self-serving bias.
- Avoidance of Conflict of Interest at The Tax Counsel: To avoid conflicts of interest, The Tax Counsel does not prepare tax returns and instead works with CPAs from other firms. This ensures that their legal advice is unbiased and focused solely on the client's best legal and financial interests, fostering trust and transparency.