IRS Private Letter Rulings | Avoiding IRS Tax Controversy | International Tax Accounting and Tax Planning
Preparation of International Tax Returns
You will always pay less taxes when you hire a real international tax expert. At International Tax Counselors, international tax is all we do. We understand the complexities and tax savings opportunities of Form 1120F, Form 3520 and 3520-A and Form 5471.
Every tax return is a tax planning opportunity. You need a CPA that does only international tax if you want all of the tax planning strategies. International tax is all that we do and we are the best at it. We spend the necessary time to ensure that your international tax planning allows you to legally avoid taxes.
I want you to move tax law to the level that tax savings are IRS risk free. I want you to have tax knowledge. The "Wealthy" use the tax laws to create wealth versus merely saving taxes.
The clients we serve typically are those that:
- need the preparation of Form 1120F, Form 5471, Form 1116, Form 3520 and Form 3520-A
- with family residing outside of the U.S.... and international businesses or sophisticated tax planning needs,
- with international tax issues, but don’t have someone on staff with the requisite expertise
- interested in offering international tax and estate planning services or
- need the preparation of Form 706NA for the non-resident estate.
We spend considerable time with you and your tax team to determine if we can help you create more wealth. Saving taxes is important, but the method must also improve your ability to create wealth. Try us out and give Brian Dooley a call now (at 949-939-3414) for a free tax brainstorming consultation.
All we do is international tax consulting. While we are an international tax accounting firm, we do not prepare financial statements or tax returns. Your CPA will see us as a partner and not a competitor. As a cross border tax accountant, we work with attorneys and accountants in other countries. We build a team to legally help you to avoid taxes.
A international tax CPA firm is different from a international tax law firm. A international tax accountant's tax planning focuses on the type of income earned by your business. International income tax planning is not about tax deduction. Foreign tax planning is about creating a clear tax accounting trail of foreign source income. You want to maximize your income tax deferral and your foreign tax credits. International Tax Counselors is unique in its innovative international tax plans. You can learn some of our methods with our videos on this web site.
As needed, we work closely with international law firms and trust companies, as well as with attorneys who specialize in cross-border probate and immigration issues and civil tax litigation to accomplish a client’s objectives. We also have relationships with captive insurance companies and family private trust companies that can facilitate international estate planning.
The nature of cutting-edge (innovative) tax planning is an absence of precedence. To eliminate risk, we apply for a "private letter ruling" (a private written agreement with the IRS that guarantees the desired tax savings without risk of penalties). We bill on a project-fee basis to eliminate any surprises about the cost of our services.
Once your needs are known, a tax team is created to fit your individual requirements. The team only includes professionals that have proven themselves to us. We collaborate and work closely with your certified public accountant and attorney.
IRS Private Letter Rulings
Creating wealth requires a solid tax foundation. Not only do our clients have the best offshore structure, they have an IRS guarantee as to the tax treatment. This is known as an IRS Private Letter Ruling and there is nothing is more solid than an IRS private letter ruling. You and the IRS have agreed on your tax strategy. With this solid platform, your cross border business can boldly go into international transactions with assurance of great tax savings.
Because the amount of taxable income is determined by the amount and character of your business, an international tax accountant is necessary. An attorney can create foreign corporations, but he does not know the flow of foreign source taxable income. The flow of the income, determines your tax.
A private letter ruling will enhance your wealth with unique international income 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:
- Maximizing your foreign tax credit with a dual resident corporation (explained on the Resource page)
- A foreign company that wants to open an office in the United States
- Cross border estate planning for using a trust (domestic or foreign)
- 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 accounting laws that few accountants or attorneys possess.
The ruling from the IRS National Office provides a certainty that no legal opinion can equal. More so, the IRS attorneys in the National Office are helpful and extremely professional.
International Tax Counselors has an exceptionally deep and broad knowledge of tax law and extensive experience in negotiating with the IRS.
Even though the process takes a few months, the IRS Nation Office will informally discuss the ruling with a few weeks.
Perfect planning avoids IRS controversy. Perfect is all that we do.
Your CPA or attorney advise no longer protects taxpayers from excessive tax penalties. 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 advisers can be assessed penalties of $100,000 or more for setting up a non–IRS-approved foreign tax shelter or listed transaction. Big tax penalties can be charged on the late filing of Form 5471 for a controlled foreign corporation or on Form 3520 for a foreign trusts.
We remove the stress from this uncertainty. 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 those who:
- Do business internationally and are entitled to the foreign tax credits
- Use foreign trusts as an estate planning tool
- Foreign corporation with U.S.... income filing Form 1120F
- Must deal with any sort of foreign inheritance or gift and filing Form 3520
- 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 and filing Form 3520-A
Peace of Mind
So we know what to do and how to get it done — and done well — for clients in situations like these:
- 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 preparing Form 1116 and Form 1118
- Immigrating into the United States
- Incorporating a foreign business in the United States
Have a question or would like to brainstorm your foreign tax plan?
Then,call me, Brian Dooley, CPA, MBT (at 949-939-3414) for a free international tax accounting consultation.