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What You Need

INTERNATIONAL TAXATION

Tax services for U.S. expatriates working across the globe and for foreign nationals working in America, including filing an FBAR, Form 5471, Form 8938 (Statement of Specified Foreign Financial Assets).

US TAX COURT REPRESENTATION (IRS APPEALS REPRESENTATION)

Taxpayers have a statutory 90-day window from the date of the notice to either agree to the government’s adjustments or file a petition with the Tax Court for a redetermination of the deficiency.

SALES TAX REPRESENTATION BY CA DEPARTMENT OF TAX AND FEE ADMINISTRATION (CDTFA)

The objective of an audit is to verify that you have correctly reported taxes or fees on your returns. In general, for all taxpayers filing returns, other than those taxpayers who do not hold a permit and elect to report use tax on the California income tax return, the statute of limitations is three years. However, for those taxpayers who fail to file returns, the statute of limitations is eight years. The California Department of Tax and Fee Administration (CDTFA) has been increasing its sales and use tax audits of small and medium-sized California companies.

VOLUNTARY DISCLOSURE FOR CDTFA (IN-STATE AND OUT-OF-STATE)

The California Department of Tax and Fee Administration (CDTFA) encourages businesses to voluntarily register and pay use tax obligations due to the State of California. The Voluntary Disclosure Program provides incentives for unregistered out-of-state companies to satisfy their use tax obligations.

The Domestic Voluntary Disclosure may be a choice for Taxpayers that are out of domestic compliance (I.e. underreported income with no foreign financial issues) and want to come into compliance and inoculate as much as possible against criminal prosecution.  

mONETIZED INSTALLMENT SALE

A monetized installment sale is an extraordinary sort of portion deal whereby a seller of appreciated assets attempts to defer U.S. Federal income tax liability over a period of years while currently receiving cash or other liquid assets via a monetization transaction, such as a loan.

AUDIT BY THE IRS AND STATE TAXING AUTHORITIES

An IRS audit is a review & examination of an organization’s or individual’s accounts and financial information to ensure information is reported correctly according to the tax laws and to verify the reported amount of tax is correct. Generally, the IRS can include returns filed within the last three years in an audit. If the IRS identifies a substantial error, the IRS may add additional years.

CRYPTOCURRENCY REPORTING

Beginning with Bitcoin, cryptocurrency has gained popularity among the investments in the recent years. There are numerous cryptocurrencies trading in the US and all over the world today which has added sophistication to the tax reporting requirements in terms of US tax perspective.

We realize that there may be voluminous transactions to analyze in order to compute the gains and losses related to cryptocurrency trades, which is very stressful. Our firm has experienced professionals who have been helping clients in reporting their cryptocurrency trades for years. We analyze your transactions and use a specialized software to compute the true and accurate data for tax reporting purposes.

INNOCENT SPOUCE RELIEF (INCLUDING SEPARATION OF LIABILITY AND EQUITABLE RELIEF)

Many married taxpayers choose to file a joint tax return because of certain benefits this filing status allows them. When filing jointly, both taxpayers are jointly and severally liable for the tax and any additions to tax, interest, or penalties that arise from the joint return even if they later divorce. Joint and several liability means that each taxpayer is legally responsible for the entire liability. Thus, both spouses on a married filing jointly return are generally held responsible for all the tax due even if one spouse earned all the income or claimed improper deductions or credits. This is also true even if a divorce decree states that a former spouse will be responsible for any amounts due on previously filed joint returns. In some cases, however, a spouse can get relief from being jointly and severally liable.

TAX PROVISION PREPARATION AND REPORTING (ASC 740)

ASC 740 (formerly known as FIN 48) is income tax accounting that requires businesses to analyze and disclose income tax risks. Due to Tax Reform, the complexity around ASC 740 has increased exponentially, which is why you would need to hire highly trained professionals.

DELINQUENT INTERNATIONAL INFORMATION RETURN SUBMISSION

Taxpayers who do not need to use the OVDP or the Streamlined Filing Compliance Procedures to file delinquent or amended tax returns to report and pay additional tax, but who:

  1. have not filed one or more required international information returns,
  2. have reasonable cause for not timely filing the information returns,
  3. are not under a civil examination or a criminal investigation by the IRS, and
  4. have not already been contacted by the IRS about the delinquent information returns
  5. should file the delinquent information returns with a statement of all facts establishing reasonable cause for the failure to file.

STREAMLINED OFFSHORE DISCLOSURE PROGRAM

The streamlined filing compliance procedures describe below are available to taxpayers certifying that their failure to report foreign financial assets and pay all tax due in respect of those assets did not result from willful conduct on their part.

DELINQUENT FBAR SUBMISSION

Taxpayers who do not need to use either the OVDP or the Streamlined Filing Compliance Procedures to file delinquent or amended tax returns to report and pay additional tax, but who:

  1. have not filed a required Report of Foreign Bank and Financial Accounts (FBAR) (FinCEN Form 114, previously Form TD F 90-22.1),
  2. are not under a civil examination or a criminal investigation by the IRS, and
  3. have not already been contacted by the IRS about the delinquent FBARs

NON-FILTER ASSISTANCE

The Non-Filer program, also known as SFR (Substitute for Return), and its automated version, Automated Substitute For Return (ASFR) were developed to contact taxpayers who have not filed tax returns voluntarily and for whom income information is available to substantiate a significant income tax liability.Internal Revenue Code Section (IRC) 6212 authorizes the Service to send a notice of deficiency when a taxpayer appears to have a filing requirement but does not comply by voluntarily filing a tax return. IRS Policy Statement 5-133, , provides a general rule that taxpayers must file six years of back tax returns to be in good standing with the IRS.

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