top of page

U.S. International Tax

Report of Foreign Bank & Financial Accounts (FBAR)

A United States citizen or Green Card Holder that has a financial interest in, or signature authority over foreign financial accounts must file an FBAR if the aggregate value of the foreign financial accounts exceeds $10,000 at any time during the calendar year.

Foreign Account Tax Compliance Act (FATCA)

The Foreign Account Tax Compliance Act (FATCA), which was passed as part of the HIRE Act, generally requires that foreign financial Institutions and certain other non-financial foreign entities report on the foreign assets held by their U.S. account holders or be subject to withholding on withholdable payments. The HIRE Act also contains legislation requiring U.S. persons to report, depending on the value, their foreign financial accounts and foreign financial assets.

Tax Compliance

The IRS generally considers three dimensions of tax compliance: filing, payment and reporting. We work with all our clients to ensure that they are fully tax compliant.

Tax Audit Representation

An IRS tax audit can sometimes be frightening. However, a tax return audit by the IRS doesn’t necessarily mean that something is wrong. We have successfully negotiated many tax issues for clients with the IRS who were subjected to a tax audit.

Federal Tax Fraud

Tax fraud occurs when an individual or business entity willfully and intentionally falsifies information on a tax return in order to limit the amount of tax liability. Tax fraud essentially entails cheating on a tax return in an attempt to avoid paying the entire tax obligation. Dayle Blair, Tax Attorney and CPA, is licensed to represent both individuals and companies in cases of tax fraud.

Federal Tax Levies

The IRS has a legal right to seize assets for taxes owing. This is known as a tax levy. If you owe the IRS and have not made any arrangements to pay your tax debt, then it is highly likely that tax levy could be issued against you. We can negotiate debt settlement arrangement with the IRS.

Federal Tax Liens

A federal tax lien is the government’s legal claim against your property when you neglect or fail to pay a tax debt. The lien protects the government’s interest in all your property, including real estate, personal property and financial assets. A federal tax lien exists after the IRS:

  • puts your balance due on the books (assesses your liability);

  • sends you a bill that explains how much you owe (Notice and Demand for Payment);

  • and you neglect or refuse to fully pay the debt in time.

Employment Taxes

One of the easiest and quickest ways to be held for a tax crime is failure to pay over taxes withheld for employees. The tax deductions employers make are regarded as trust funds because they actually hold the funds in trust until they are paid over to the government. We ensure that your business does the correct deductions and guide companies in making timely payments of these deductions.

Innocent Spouse Relief

Innocent Spouse Relief provides you relief from additional tax you owe if your spouse or former spouse failed to report income, reported income improperly or claimed improper deductions or credits.

Injured Spouse Relief

According to the IRS, if you file a joint return and all or part of your refund is applied against your spouses’ past-due federal tax, state income tax, child or spousal support or federal non-tax debt, such as a student loan, you could be entitled to injured spouse relief.

Non-Filers Tax Returns

If you have delinquent tax returns or are a non-filer, there are several areas where you are at a disadvantage. For example, if you have multiple delinquent tax returns, most of which show balances due, and one or two with refunds, if you fail to file those with refunds for 3 years, the refunds will be lost. The IRS will still come after you for those with balances due, but you won’t get the refunds or be allowed to use them to offset the balances due. This rule is very one sided and puts the impetus on you to file any delinquent tax returns. Non filing of returns is a criminal offence which could result in civil  and criminal penalties.

Offer In Compromise

According to the IRS an offer in compromise allows you to settle your tax debt for less than the full amount you owe. It may be a legitimate option if you can’t pay your full tax liability, or doing so creates a financial hardship. We make a professional analysis of your tax debt and negotiate with the IRS.

ITIN Certified Acceptance Agent

Dayle Blair, US tax attorney, is authorized to submit ITIN applications.

IRS Tax Transcript Requests

We can access and deliver to you your IRS transcripts as far back as 1990.​​

High Tax Kick-out

It may allow companies in high tax jurisdiction greater then 18.9% not to pay the GILTI tax.

GILTI Calculation​

May be required for owners of CFC's to include their ownership interest as part of their ordinary income when filing their US Tax returns.

Repatriation Tax​

U.S. tax payers may be required to pay a one time tax for all accumulated income between 1986-2017.

Tax Litigation before the IRS

We provide legal representation or expertise regarding civil tax and criminal tax issues in the US courts.

bottom of page