In 2010 the U.S. Tax Court ruled that your long time CPA or attorney is no longer “independent.” His/her advise no longer protects taxpayers from
excessive tax penalties.
Taxpayers relying on an accountants or attorney’s advice regarding international transactions and cross border estates planning are not protected
when the advisor is paid a fee for the tax plan.
The Tax Court has ruled that such advice is no longer sufficient to avoid IRS penalties, which are now often 30% to 50% of the amount in question.
As a result, these individuals can end up owing much more in taxes and penalties than necessary or discover a failure to file a required IRS form.
And their advisors can be assessed penalties of $100,000 or more – or even be thrown in jail – for setting up a non-IRS-approved foreign tax shelter
or listed transaction.
Persons looking for tax-advantaged retirement planning are best advised to explore products that are explicitly compliant with IRS or local government tax regulations.
For clients with businesses, investments or employment in another country, cross border tax planning is critically important.
Without it, they are subject to costly triple taxation, find themselves in violation of tax laws or simply pay more tax than necessary (usually because of hidden tax known as the “Branch Profits Tax”)
These services are especially beneficial for persons:
- Living, working or investing abroad
- Having partners or family members abroad who may leave them money
- Owning a business that operates in a foreign country
- Establishing an international inheritance trust
- Maximizing foreign tax credits
- Immigrating into the United States
- Incorporating a foreign business in the United States
- Want to Guarantee IRS Compliant Private Placement Life Insurance or Annuity Policy without FATCA issues.
- That need to 1035 Transfer OUT of a FATCA non-compliant Life or Annuity Policy to one that has NO FATCA issues!
- Use foreign trusts as an estate planning tool without FFI or FATCA issues.
- Set up a captive insurance company that is owned by
- the client and insures the client without FATCA issues.
- Must deal with any sort of foreign inheritance or gift
- Enter into a cross border license of intellectual property or other intangible products
- Want to reform an existing trust while maintaining its estate tax GST benefits
These Services are especially beneficial to non-U.S. companies with dual tax status:
- A foreign company that wants to open an office in the United States
- Estate planning using a trust (especially an offshore trust)
- A captive insurance company
- Use of a controlled foreign corporation
An IRS Private Letter Ruling will enhance your wealth with unique tax planning that only the IRS can approve. Providing a written IRS ruling on our tax planning strategy for you is the only way to guarantee the tax benefits of implementing it- and to avoid the penalties that can result from a negative IRS finding.
