Avoiding IRS tax controversy

Perfect planning avoids IRS controversie. Perfect is all that we do.

In 2010 the 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 accountant’s 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.

We remove the stress from this uncertainity. To avoid such unpleasant surprises, International Tax Counselors collaborates with accountants, attorneys and trust companies, both here and abroad, to obtain a written IRS private ruling guaranteeing the taxpayer’s tax benefits. Obtaining a written IRS ruling on the tax plan completely removes the risk of controversy.

Our services are especially beneficial for clients who:

Do business internationally and are entitled to the foreign tax credits
Use foreign trusts as an estate planning tool
Set up a captive insurance company that is owned by the client and insures the client
Must deal with any sort of foreign inheritance or gift
Enter into a crossborder license of intellectual property or other intangible products
Want to reform an existing trust while maintaining its estate tax GST benefits

Often, a voluntary disclosure can mitigate danger of an IRS audit. Working with your attorney, issues such as unreported listed transactions can be fairly resolved with minimal a tax penalty.

International Tax Counselors has exceptionally broad and deep expertise in cross-border tax and estate planning. Our principal, Brian Dooley, CPA, has successfully obtained 100s of IRS rulings and agreements for clients on international tax plans. In addition, he has provided expert testimony on various tax and trust issues to the U.S. Department of Treasury, the U.S. Tax Court, the U.S. Senate Finance Committee and the U.S. House Ways and Means Committee