Diosdi & Liu, LLP

Focus and practice areas

The work here centers on tax, and it splits into two familiar tracks. One track is tax controversy: audits, administrative appeals, and litigation with the IRS and state agencies. The other is planning, where the firm writes tax opinions and structures matters before any dispute starts. Diosdi & Liu, LLP also uses the name SF Tax Counsel, and both names point to the same San Francisco firm.

The controversy side covers a wide span of problems. The firm handles tax collection matters, employment tax disputes, and the dischargeability of tax in bankruptcy. It also represents clients in offshore voluntary disclosures and FBAR penalty cases. In my opinion, that mix reads as a firm built around problems that reach across borders.

Planning is the quieter half of the work. Tax opinions, for instance, set out how a transaction should be treated and why, and clients often rely on them when they take a position that could later be questioned. Good planning aims to keep a matter out of controversy in the first place, and a firm that also litigates knows what a weak position looks like when it reaches a court. That feedback loop between planning and dispute work is one of the more useful things a firm that does both can offer.

How a tax dispute moves

A tax dispute usually moves in stages, and knowing the stages helps explain what the firm does. It often starts with an examination, where the IRS questions items on a return. If the two sides disagree, the matter can go to the agency's administrative appeals office, which reviews the case apart from the auditor. When that step does not settle things, the dispute heads to court.

The firm has tried cases before the United States Tax Court, the Court of Federal Claims, and U.S. district courts. Those three forums each work differently. In the Tax Court, a taxpayer can dispute the IRS before paying the assessed amount. In a district court or the Court of Federal Claims, the usual route is to pay first and then sue for a refund. Where a case is filed shapes both cost and timing, so the choice of forum is part of the strategy. A firm that works at every stage can stay with one matter through each step.

Collection matters raise a different question: how to pay or resolve a bill the taxpayer already owes. The dischargeability of tax in bankruptcy fits here, since some older income taxes can be wiped out in bankruptcy while newer ones and certain penalties survive. The timing rules are technical, and small differences in dates can change the result. The firm handles this corner as part of its controversy work.

The international tax side

A large part of the firm's work is international tax, and the firm says this is why it was organized. It advises U.S. clients on outbound issues such as Subpart F, GILTI, and FDII. These are the rules that decide how income earned through foreign companies gets taxed at home. The firm also prepares international information returns, including Form 5471 for foreign corporations and Form 3520 for foreign trusts and large foreign gifts.

For foreign clients, the work turns inbound. The firm counsels on FIRPTA, which governs how non-U.S. investors are taxed when they sell U.S. real estate. FIRPTA also puts a withholding duty on the buyer, so both sides of a U.S. property sale can need advice. It also handles cross-border mergers and acquisitions. As a reviewer, I read this as the center of what the firm points to when it describes an unmet need it set out to serve.

These filings carry their own penalty regime. A late or missing Form 5471, for example, can trigger fixed penalties before any tax is even in question. That is part of why the reporting work and the penalty defense work tend to travel together in a firm like this one.

Offshore accounts and criminal defense

Offshore disclosure work follows its own path. Taxpayers with unreported foreign accounts can come forward through established IRS programs, and the terms depend on whether the failure to report was willful. The FBAR itself is an annual report of foreign financial accounts filed with the Treasury, and it is separate from the income tax return. FBAR penalties can be steep, and the defense often turns on that willfulness question.

For non-willful cases, the IRS has offered streamlined procedures with reduced penalties. For willful conduct, the stakes rise, and the criminal question comes into play. Sorting a client into the right track is much of the early work, and it shapes everything that follows.

The criminal side is its own line of work. The firm represents people in white-collar criminal cases and in IRS criminal investigations. Anthony Diosdi's background includes white-collar criminal defense alongside tax controversy and government regulatory matters. Cases like these often begin quietly. A civil audit turns into a criminal referral, and having both civil and criminal skills under one roof helps the client who reaches that point.

The two partners

Anthony Diosdi is one of the two partners, and his education runs deep into tax. He holds a B.S. in political science from Florida Atlantic University, a J.D. from Quinnipiac University School of Law, and an LL.M. in tax law from Golden Gate University School of Law. The LL.M. is an advanced tax degree, and it points to a deliberate choice to concentrate on the subject.

Kerrin Liu is the second partner. She studied at the University of California College of the Law, San Francisco, and graduated in 2014. Her practice focuses on tax law, including business tax matters. Both partners are listed at the San Francisco office. With two partners carrying the caseload, a client is likely to deal directly with one of the named attorneys.

Offices and reach

The firm keeps three offices. The main one is in San Francisco, with further offices in Pleasanton, California, and Fort Lauderdale, Florida. The firm says client meetings are available at each. The Florida office gives the firm a base on the East Coast, which fits a client roster that includes foreign investors and cross-border deals.

The site does not list a founding year. What the pages do show is a tightly drawn firm. Diosdi & Liu, LLP handles tax in its civil, criminal, and international forms, and it does so through two named partners working from San Francisco, Pleasanton, and Fort Lauderdale.