Our law firm offers sophisticated tax planning services to businesses and individuals that are designed to (1) take advantage of all opportunities to minimize taxes and (2) avoid future tax issues with the Internal Revenue Service.
Our lawyers counsel startup companies, small businesses and large corporations on issues regarding:
– Real estate sale or purchase
Multinational clients also regularly seek our advice on structuring operations to minimize U.S. taxes and filing requirements as well as planning for the tax-efficient repatriation of future earnings and reallocation of capital.
Change – in tax laws, market conditions and family business situations – represents one of the most significant wealth management challenges for individuals and families. Our attorneys advise business owners, high net worth individuals and other clients on individual income tax strategies.
The U.S. federal government imposes three major taxes: the Federal Income Tax, the Federal Estate Tax, and the Federal Gift Tax. Local governments, such as states and municipalities, may also impose their own taxes, but the federal tax rates are significantly higher than the state and municipal tax rates.
The United States taxes its citizens and tax residents on their worldwide income. The United States also taxes non-residents on income derived from the United States, including income from a U.S. trade or business and income from certain investments in U.S. real property.
Because of the US worldwide tax system, persons considering moving to the United States should strongly consider contacting us before their move so we may help them implement structures to reduce their income and estate taxes.
Tax Compliance – Penalty Removal
United States citizens and tax residents are also obligated to file tax returns and disclose their domestic and foreign accounts and assets to the IRS.
If you are facing penalties for not filing or paying your taxes on time, or for failure to disclose overseas accounts or assets, you may be able to get those penalties removed through penalty abatement or penalty adjustment.
Abatement refers to eliminating an assessed tax liability and an adjustment references reducing or altering an assessed liability.
There are several methods to consider with penalty abatement. One method is reasonable cause. If there is a ‘reasonable cause’ for abatement or adjustment, the IRS may be willing to review the penalties and make adjustments.
Each taxpayer has unique circumstances, but some examples of reasonable cause may include:
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