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Tax & Business Consultants When a complicated or even simple tax issue comes up for our client, we are just a phone call away. Sometimes you need another opinion. And sometimes having that second opinion come from a tax and legal perspective can really speed up the decision-making process.

Tax Compliance and Planning for the Small Medium-Sized Business (SMB): Whether you are a US person doing business overseas, or a foreign owned business doing business the United States, if you are doing business internationally it is essential that you understand how Tax Reform changed the rules for foreign income and asset reporting. GILTI, Transition Tax, and BEATs regimes and new downward attribution rules are

Tax preparation: We got our start by fixing problems others created. This meant that our work always has been heavily scrutinized by the IRS. So invariably we perform to the highest standard. For businesses for other tax firms they can rely on our preparation of intensely consequential foreign reporting form likes Form 5471, Form 5472, Form 3520, 3520-A, ,Form 8621, Form 8938.

Accounting Support: All foreign accounting statements must be translated into GAAP or the forms may be deemed substantially incomplete. We help our clients convert documents into the specific international standard used into GAAP.

Audit & Examination Experts: Even for taxpayers who been through audits successfully over the years, receiving an examination letter can still be an awful experience. Our job is to not only handle the technical aspects of the examination, but also be a source of strength in what can be a fairly arduous process.

Audit Appeals and Reconsideration: If your audit did not turn out the way you hoped, it is not the final answer. While IRS examiners like to pretend they are the final authority of items of dispute, the fact is that they are the first word, not the last.

FBAR & Informational Return penalty mitigation: The IRS has made it very clear that they are going to be assessing FBAR penalties and Informations Returns penalties like Form 5471, Form 3520, Form 3520-A, Form 926, Form 8865, Form 8938 as aggressively as possible. We believe them. We’ve already seen a flood of cases where examiners have assessed penalties yet appear to be quite confused as to what to look for.

Tax Court litigation: Truth be told tax court is the last place we seek to find justice, but sometimes it has to be done. The reason is that the tax courts just aren’t as flexible as you would hope. And the IRS’s attorneys fight hard not to get any bad precedent and are perfectly fine kicking your case out on a technicality if they can. But this fact — the fact the IRS lawyers want to avoid any bad precedent can be used to your advantage if you know how.

Offshore Voluntary Disclosures Practice and Streamlined Disclosure Procedures: Starting in 2009, our tax lawyers have been the leaders in making offshore disclosures. We have helped thousands of taxpayers get into compliance with the IRS, often involving difficult technical tax issues, along with helping to calm the intense concerns the process can stir.

Expatriation: In order to leave the US, it is a bit more complicated than just renouncing your citizenship. The IRS requires a Form 8854 to be filed. If you are not a covered expat, the process is relatively straight-forward. However if you are a covered expat the process can be a bit more daunting. No matter the situations, we can help you make sure there are no problems with your expatriation.

US Estate Tax issues on non-US persons: While most Americans are aware of the estate tax on US persons, many are completely unaware that there is also an estate tax on the US-owned property of non-US persons. This estate tax often can surprise the heirs of foreign investors in US real estate and stocks. The good news is that there are solid-workarounds to this little known trap.

Tax Settlements, workouts and negotiations: Sometimes the IRS sends a tax bills that is not quite manageable. Our experience staff are experts at pushing the boundaries of what the IRS will accept as repayment through various sue of installment agreements, lump sum offers, and offers in compromise.

Payroll tax issues: If your business has a tax bill for past due payroll deposits, the stakes are raised. IRS Revenue Officer across the country are trained to make “first contact” by visiting you in person. What you do after this first contact can be critical to the success of your business.

Asset & passport protection: The IRS is now directing the US State Department to revoke and deny passports of taxpayers who are deemed to be “seriously delinquent.” The problem is that this law affects taxpayers with global business rather significantly. Additionally, so many taxpayers have failed to file properly for years. If audited, the IRS can present them with a tax bill that can put them over this $50,000 figure quite easily — in penalties alone.

Client Reviews
Thank you so much for all your help in dealing with our Streamlined Disclosure submission - your expert guidance and friendly approach were invaluable in getting us through the complicated processes. CK
You are the only tax professionals I’ve dealt with who have real knowledge about these off-shore issues. I can’t thank you enough. AD
Gratitude and appreciation are the words that come to mind when I consider the law firm that you have built, and the community that you have created, to protect the people, your clients. LB