We focus on Tax Compliance, IRS Collections Defense, and Tax Strategies for US taxpayers and foreign taxpayers alike.

Tax Planning

Our firm works hard in forecasting our client’s tax liability and formulating ways to reduce it. We pride ourselves in strategizing through various methods, such as using wealth transfer techniques to reduce our client’s tax obligations legally. Especially in the case of a business sale or transaction, we recommend you involve us in the process as soon as possible.

So you have a newly form limited liability company LLC: what do you do now? How is your LLC taxed? This is a very important question. The IRS has promulgated default rules. Generally, a single member LLC is disregarded for federal income tax purposes, but is a corporation for employment and excise taxes. The biggest mistake I see people make is they form an LLC because someone told them it was a good idea. Perhaps you should consider whether a corporation is better. Furthermore, LLCs can make a tax election in many cases to be treated as a corporation or s-corporation. How does this affect you? A very big mistake I see people make is that they fail to keep a copy of their election application and IRS acknowledgement letters. This makes it very difficult in the future for attorneys to deal with certain issues. Those founding documents should be retained permanently.

Tax Asset Protection
Investment Tax Planning
Assistance for Un-filed Returns

Net Unrealized Appreciation
Retirement Taxes
Charitable Giving Strategies

IRS Representation

As a Tax Lawyer, We understand how you may feel if you or your loved one is struggling to resolve an IRS matter. As a result, we provide our clients with the knowledge and expertise to assist and resolve the issue as quickly as possible. We are committed to working to solve the matter with the IRS. We provide thorough and exhaustively-prepared representation and efficient advocacy to every case.

How the IRS Process Works

The IRS process works as follows:

(1) Examination Level / Audit – This is where the IRS examines an income tax return or other type of tax return, to determine whether the numbers on the return match the transactions and dealings of the taxpayer.

You can discover more about this process by reading IRS publication 1. A quick note, when researching IRS publications and forms, its best not to choose the first .pdf that pops up in search results from Google or Yahoo. Go to the publication’s official home page, which will have the most recent version. The reason is that the IRS updates the publications and forms frequently, and Google may just have the most searched form that was recently updated. Click on Publication 1 for an example of a publication’s homepage. If the Form does not have a homepage, search it through www.irs.gov and look for the most recent revision date under forms. If you are looking for prior year forms, then search accordingly at www.irs.gov.

At the exam level, the examiner has authority but less. His or her function is to determine whether the return is correct and whether any additional tax is due or you are entitled to a refund, which they will give you. Generally speaking, I would never agree to the imposition of a penalty after an audit. So never sign an audit report unless you have agreed to the report and findings and there is no penalty.

2. Appeals – If you do not agree with the outcome of the audit, you can go to appeals. The IRS Office of Appeals is actually an independent office separate from the examination level and the appeals officer will have no involvement in your prior audit. So you get a fresh start. Appeals has more discretion to resolve matters. THis is your best chance to resolve your case.

3. Tax Court – If you disagree with appeals, you can timely petition the tax court. In tax court, there is not a jury, but a judge who has experience in tax matters. The IRS is represented by counsel as well. It could be tougher to get a settlement in tax court, but since you have preserved your rights, you have the opportunity to present your case to an appointed Judge. In the case of Collection Due Process Appeals, you would have the right to present another collection alternative to the IRS and go back to appeals in some cases.

What is important: From my perspective, it is important to preserve your rights. Some people think by filing an appeal they are offending the IRS. Not true. You are trying to preserve your rights, and work administratively through a process that was designed to allow you to resolve your differences with the IRS in a professional and courteous manner. One of the biggest misnomers is that the IRS is hunting you down and trying to destroy you are bankrupt you. I have found this to be farr from the truth. The truth is, if you navigate their system, they will help you resolve your tax matters, with opportunities at the exam level, the appeals level, and beyond.

Offers in Compromise
Tax Lawyer
Installment Agreements
Levies & Wage Garnishments
Collection Due Process Hearings
Injured Spouse Allocation
Innocent Spouse Relief Claims
IRS Statute of Limitations
Claims for Refund & Refund Litigation
Penalty Abatement Requests
Federal Tax Liens
Intent to Levy
Collection Due Process

Equivalent Hearing
Doubt as to Collection
Doubt as to Liability
Exceptional Tax Circumstances
Uncollectable Taxpayers
Lien Subordination
Lien Discharge
Lien Withdrawal
Tax Preparer Penalties
Tax Promoter Penalties
Individual & Corporate Tax Audits
IRS Appeals & Tax Court
Trust Fund Recovery Penalties

International Tax

As an International Tax Attorney, we pride ourselves in handling foreign taxpayers or corporations doing trade or business within the United States. A U.S. citizen or a resident alien of the United States that lives abroad, is taxed on his or her worldwide income. However, you may qualify to exclude from income up to an amount of your foreign earnings that is adjusted annually for inflation. We protect our clients from double tax to the U.S. Government and consulting them on their foreign tax planning.

Issues

  • Forgot to file FBAR FinCen 114
  • Forgot to File 3520 3520-A Report of Foreign Inheritance / Gift / Trust
  • Forgot to File entity election (check-the-box election) Form 8832
  • Improper For 2555 Foreign Earned Income
  • Failed to report worldwide income
  • overstayed substantial presence test
  • Failed to claim foreign tax credits Form 1118
  • misunderstood automatice extension of 2-mos to file return for foreigners
  • misunderstand additional extension to file return
  • Did not answer Schedule B questions correctly
  • Did not report foreign assets Form 14452
  • Did not file Form 8938
  • Did not understand W-8BEN
  • Don’t understand PFIC Form 8621
  • Don’t understand CFC Form 5471

International Taxpayers
Foreign Account Compliance Act (FATCA)
Report of Foreign Bank and Financial Account (FBAR)
Offshore Disclosures
Voluntary Disclosures
Foreign Taxpayers
Tax Treaties
Income Deferral
Foreign Tax Credits

Foreign Earned Income Exclusion
Foreign Housing Exclusion
Territorial Incorporation Exclusion
Interest Charge Domestic International Sales Corporation (IC-DISC)
Foreign International Sales Corporation (FISC)
Passive Foreign Investment Companies (PFIC)
Controlled Foreign Corporations (CFC)

Our firm has the experience and knowledge of US tax laws and how your personal or business issue can be resolved with the IRS. We prefer to avoid tax problems for our clients through advance planning and strategic advice, and will look for legal methods of minimizing your tax bill.

If you have a tax issue that you have avoided, or are looking for innovative solutions to paying excessive taxes, you are invited to contact us for a free consultation. Our goal is to save you time and money regardless of your financial situation or taxable status.

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