IRS private letter rulings

CPA's are missing an opportunity to provide their clients with the value added service of a private letter ruling. Most importantly, by not getting their client a ruling, the client never had peace of mind. When a client engages in sophisticated tax planning involving substantial sums of money, a private letter ruling from the IRS is needed.

A private letter ruling will  enhance your wealth with unique tax planning that only the IRS can approve.  We collaborate with your CPA or an attorney.  Obtaining a written IRS ruling on a sophisticated tax planning strategy is the only way to guarantee the tax benefits of implementing it — and avoid the penalties that can result from a negative IRS finding in cases involving matters or entities like these:

    * A foreign company 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 

Admittedly, conducting the legal research and working through the complex steps required for a valid ruling is time consuming. Plus, it requires a highly specialized knowledge of U.S. and international tax laws that few accountants or attorneys possess. But a ruling from the national IRS office provides a certainty that no legal opinion can equal.

International Tax Counselors has an exceptionally deep and broad knowledge of tax law and extensive experience in negotiating with the IRS on private letter rulings. Our private tax-knowledge base includes more than four million pages of articles on IRS regulations, tax litigation and international taxation. Also, we have strong relationships with IRS attorneys in Washington, as well as with many foreign law firms and trust companies.