When a client engages in sophisticated tax planning involving substantial sums of money, foreign investments, trusts or uncommon tax shelters, a private letter ruling from the IRS is needed.


Why?  For two important reasons.

 

First, as a CPA or an attorney collaborating with us, you earn a higher fee with no IRS risk. Second, obtaining a written IRS ruling on a proposed 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.

 

As a result, we have succeeded in obtaining favorable rulings and voluntary disclosure agreements for hundreds of clients, and are ready to do the same for yours. Please let us know how we can be of service.

When a client engages in sophisticated tax planning involving substantial sums of money, foreign investments, trusts or uncommon tax shelters, a private letter ruling from the IRS is needed.


Why?  For two important reasons.

 

First, as a CPA or an attorney collaborating with us, you earn a higher fee with no IRS risk. Second, obtaining a written IRS ruling on a proposed 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.

 

As a result, we have succeeded in obtaining favorable rulings and voluntary disclosure agreements for hundreds of clients, and are ready to do the same for yours. Please let us know how we can be of service.