CANADA'S TAX & BUSINESS LAWYERS
We Deal with
US Federal, State
and Local
Tax Controversy
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We provide assistance in collection matters, offer in compromise, penalty abatement, IRS examination, IRS appeals, IRS audits, and U.S. Tax court representation.
Whether you were born in the U.S., are a dual-citizen (even if you have never stepped foot on U.S. soil), own property or rental property in the U.S., or even snowbird in the U.S., there may be international tax consequences that you may not be aware of.
01.
U.S. citizens are required to pay tax on their worldwide income, despite where they reside. Rather than gamble with the IRS, it is important to determine your requirements as US Citizens living abroad. Although there are treaties in place to protect you from paying double taxation in numerous countries, treaties do not act as a shield; you are still responsible for knowing your rights and responsibilities as a taxpayer.
02.
Even if you do not think you are a U.S. Citizen, beware, as the U.S. taxman may deem you a resident alien by means of the substantial presence test, determined by the length of time you have spent in the U.S. among other factors. Those who winter in the U.S. must pay particular attention to such rules, as U.S. tax laws may apply.
03.
There are stern consequences for failing to provide U.S. Information Reporting to the IRS, including penalties for failing to file simple reports. For instance, for those required to file FBARs (Report of Foreign Financial Accounts over a specific amount), penalties begin at $10,000 and up to $60,000 per failed report. There may also be criminal penalties for non-compliance.
04.
Avoid wilful failure to report. Let us help you with FATCA (Foreign Account Tax Compliance Act) compliance. Contact us and we can help determine whether you are required to file and report in the U.S.
05.
It is important for you to know your U.S. personal income tax obligations and U.S. information reporting obligations. Learn what forms and returns need to be filed both in Canada and the U.S. and how international data exchange affects you.
06.
We can help you come forward through various channels; including helping to determine whether you qualify for the IRS offshore voluntary disclosure program, IRS quiet disclosure, or IRS streamlined filing compliance program.
Dealing with an IRS tax controversy and need help with dispute resolution?
Whether your client is trying to expand their company into the United States, have tax issues, or require cross-border estate planning, Barrett Tax Law is here to assist. Don’t let your client go unassisted, come to us. We have the expertise you have been looking for to help assist your clients further.
For instance, do you have a client who is considered a U.S. Deemed Resident Alien and is looking to learn more about how to avoid paying taxes on their worldwide income in the U.S.? Our lawyers can assist in explaining to the process of qualifying for non-resident status by reason of a Treaty Exemption and help to determine what forms to file in order to protect their rights in the future. Together we can provide your client the building blocks necessary to succeed.
Dealing with an IRS tax controversy and need help with dispute resolution?
Whether your client is trying to expand their company into the United States, have tax issues, or require cross-border estate planning, Barrett Tax Law is here to assist. Don’t let your client go unassisted, come to us. We have the expertise you have been looking for to help assist your clients further.
For instance, do you have a client who is considered a U.S. Deemed Resident Alien and is looking to learn more about how to avoid paying taxes on their worldwide income in the U.S.? Our lawyers can assist in explaining to the process of qualifying for non-resident status by reason of a Treaty Exemption and help to determine what forms to file in order to protect their rights in the future. Together we can provide your client the building blocks necessary to succeed.
Florida
Whether you own property down in Florida, keep a dog on your premise, or simply spend your winters vacationing; there are many legal nuances that are specific to your situation.
Have you arranged your affairs to account for cross-border estate planning? Perhaps you have a holographic will that may be fine in Toronto, but may not hold up in Florida. Perhaps you wish to transfer gifts or are a recipient of gifts and are not sure how or if you should be taxed. Contact us to help with your personal wealth planning.
Find out if it benefits you to become or remain a US Citizen. Let us help you with your citizenship and residency planning. Would having a homestead help with your estate planning? Are you missing out on being taxed at the same rate as Florida residents? Do you spend a significant time living in the U.S. but don’t want to pay tax as if you are a U.S. Citizen? Learn how to become a deemed or incidental U.S. resident for tax purposes or how to avoid this from occurring.
Cross-Border
We also help with international tax planning for companies. Contact us to discuss Canada-U.S./ Cross-Border corporate tax advice and cross-border business structuring and investment. We would be happy to help you with cross-border corporate organization or reorganization to optimize your tax efficiency.
Cross Border Estate Planning;
Business Expansion to the U.S.;
Corporate Tax Planning;
U.S./Canada Tax Advice;
Personal Tax Planning;
U.S. Citizenship & Residency Planning;
Tax Controversy;
U.S. Information Reporting Requirements;
U.S. Deemed Residents;
Voluntary Disclosure Programs; and
ITIN or EIN registration.
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