Tax Law
This area of law is particularly complex and requires a high level of training. For this reason, our attorneys train continuously and hold a significant amount of experience in the field of tax law. THEVOZ & Partners is a law firm with offices in Austin and Lausanne specializing in the provision of tax and legal services to individuals and companies in the United States and Europe. We help clients navigate a litany of domestic and international tax issues ranging from compliance to planning and even litigation. We understand that each client has unique needs and goals, and we pride ourselves on taking a personalized approach to tailoring our services to meet those needs.Tax Compliance
Within Tax Compliance, we specialize in the following:
Non-Residents who are not tax-compliant have two ways to get compliant
Many people are surprised to learn that, even if you do not live in the United States, certain taxpayers with income earned in other countries still must file and pay taxes in the US. These taxpayers include US citizens, permanent residents (green card holders), and people with a substantial presence in the United States (i.e., if they lived in the US for 183 days or more in the past three years according to a specific IRS formula. See the details here. These are all “US persons for tax purposes.” Even if the income is earned outside the United States, they must file and pay taxes on that income with the IRS.
Often, these people discover several years down the road that they have an obligation under US tax laws but they failed to file a tax return in a timely fashion. This means they are non-compliant with their taxes for those years. For people who simply weren’t aware of their obligation to pay US taxes on that income (sometimes considered non-willful), there are many different methods for getting compliant under the US tax law. One of the methods is the streamlined foreign offshore procedure. The streamlined foreign offshore procedure is fairly complex and requires gathering significant amounts of paperwork and filling out relevant forms, such as the FBAR and Form 8939. In addition, an individual who would like to use this program is required to file three years of US tax returns and six years of FBARs. If accepted to the streamline offshore procedure, the taxpayer could see significant benefits. If the IRS accepts that the taxpayer is following the proper procedure and correctly submitting all of the paperwork required, they will not have to pay penalties for non-compliance such as failure-to-file and failure to pay penalties, accuracy-related penalties, information return penalties and FBAR penalties. However, the taxpayer shall be required pay any tax liabilities.
Willful non-compliance
The IRS takes a darker view of taxpayers who were willfully non-compliant; in other words, taxpayers that knew they had to file US tax returns and pay tax on foreign income but failed to do so. The IRS has another avenue for these types of taxpayers who seek to get compliant, Voluntary Disclosure, but the program requires timely disclosure and full cooperation with the IRS in order to mitigate exposure to criminal prosecution. The process for willfully non-compliant taxpayers initially requires the taxpayer to obtain a pre-clearance from the IRS criminal investigation to determine whether the taxpayers is eligible. Upon receiving pre-clearance confirmation, the taxpayer is required to provide additional information. Needless to say, taxpayers judged to be willfully non-compliant must meet a difficult standard to get compliant. The potential penalties for these taxpayers include a civil fraud penalty that can be substantial. However, there are several items that are at the discretion of the examiners, providing willfully non-compliant taxpayers with an incentive to fully cooperate with the IRS and make restitution in a timely manner.
It is highly beneficial for a US person for tax purposes to seek the counsel of an international tax lawyer before using the procedure mentioned above. The IRS is dedicated to having taxpayers pay what they owe promptly and completely, and the rules and paperwork are complex and make people anxious. THEVOZ & Partners will evaluate each taxpayer’s situation and assist with IRS programs to be compliant with US tax laws.
THEVOZ & Partners has the knowledge and experience necessary to help its clients navigate streamlined compliance procedures by:
Relinquishment of US Nationality
Cross Border Tax Planning
U.S. and Switzerland maintain close friendship and trade relations. Switzerland is known for its neutrality, legal clarity, and political stability. Besides, its top-notch financial infrastructure and beautiful mountains allow Switzerland to attract talent from all over the world. With offices in both U.S. and Switzerland, we can help our clients nagivate cross-border tax planning efficiently and professionally.
Within Cross Border Tax Planning, we specialize in:
U.S. Persons Operating Abroad
- Controlled Foreign Corporations
- Passive Foreign Investment Company
- Foreign Grantor Trust
- Foreign Gifts
Foreign Persons & Entities’ Activities in the U.S.
Tax Controversy
Within Tax Controversy, we specialize in:
Federal Tax Controversies
Internal Revenue Service (IRS) plans on hiring more employees. Many of these will be focused on ensuring that taxpayers are compliant. Whether in the form of the IRS’s Automated Under Reporter program (AUR), a correspondence examination, or an in-person audit, these employees are always reviewing and verifying tax filings. Guided by the extensive Internal Revenue Code and one of the largest workplace handbooks, the Internal Revenue Manual (IRM), these individuals have a wide variety of tools at their disposal. Anyone filing a return may be examined and subject to an audit and everything that comes with it. Dealing federal tax controversy requires an experienced attorney that can help navigate you through the complexities of the tax law and the intricacies of an examination by the IRS.
Let Thevoz & Partners stand by your side and fight for you. Don't face the IRS all alone because you do not have to. Our experts in tax controversy can provide both individuals and institutional clients with a knowledge, support, and experience to dispute a tax controversy. Working with a tax law professional can help you secure a more favorable outcome when dealing with matters involving the IRS.
Give us a call or contact us to let us assist you with your tax concerns at the federal, international, and cross-border level.
What is Tax Controversy?
Tax controversy is an area of litigation related to tax disputes between the U.S. Internal Revenue Service and taxpayers. Tax law attorneys provide legal services that any taxpayer can benefit from when it comes to audits or litigation. Controversies can either be civil or criminal. Civil controversies are by far the most common, but it is worth noting that civil cases can become criminal cases if a taxpayer is not careful or if the conduct was flagrant and criminal.
These professionals can also negotiate settlements on your behalf and resolve the case in the most efficient and least time consuming manner. Tax disputes can occur at the local, state, federal, and even international level. Individuals, businesses, corporations, trusts, and estates may all be subject to tax controversy. We have experience dealing with a range of issues including: second pillar accounts, unreported income, earned income tax credit, estate and gift tax (death tax), and itemized deductions, just to name a few. We can help you navigate a civil matter in an efficient way.
How THEVOZ & Partners Can Help?
The experienced and trustworthy tax law attorneys at our firm have years of experience in handling federal, cross-border, and international tax disputes. Through a collaboration of highly trained and motivated professionals, we can best assist individuals and businesses needing guidance in legal tax matters involving the IRS and other tax authorities by providing:
Our team offers you support through federal examinations, representing taxpayers and resolving tax disputes as efficiently as possible. In addition, we will represent you before the Office of Appeals. Through collaboration with local client service teams, we can manage tax controversies before they grow out of control. We will compile evidence and present your case in the best possible light.
Furthermore, there are three strong reasons why selecting a tax law attorney from THEVOZ & Partners would benefit you by:
Within Tax Compliance, we specialize in the following:
Non-Residents who are not tax-compliant have two ways to get compliant
Many people are surprised to learn that, even if you do not live in the United States, certain taxpayers with income earned in other countries still must file and pay taxes in the US. These taxpayers include US citizens, permanent residents (green card holders), and people with a substantial presence in the United States (i.e., if they lived in the US for 183 days or more in the past three years according to a specific IRS formula. See the details here. These are all “US persons for tax purposes.” Even if the income is earned outside the United States, they must file and pay taxes on that income with the IRS.
Often, these people discover several years down the road that they have an obligation under US tax laws but they failed to file a tax return in a timely fashion. This means they are non-compliant with their taxes for those years. For people who simply weren’t aware of their obligation to pay US taxes on that income (sometimes considered non-willful), there are many different methods for getting compliant under the US tax law. One of the methods is the streamlined foreign offshore procedure. The streamlined foreign offshore procedure is fairly complex and requires gathering significant amounts of paperwork and filling out relevant forms, such as the FBAR and Form 8939. In addition, an individual who would like to use this program is required to file three years of US tax returns and six years of FBARs. If accepted to the streamline offshore procedure, the taxpayer could see significant benefits. If the IRS accepts that the taxpayer is following the proper procedure and correctly submitting all of the paperwork required, they will not have to pay penalties for non-compliance such as failure-to-file and failure to pay penalties, accuracy-related penalties, information return penalties and FBAR penalties. However, the taxpayer shall be required pay any tax liabilities.
Willful non-compliance
The IRS takes a darker view of taxpayers who were willfully non-compliant; in other words, taxpayers that knew they had to file US tax returns and pay tax on foreign income but failed to do so. The IRS has another avenue for these types of taxpayers who seek to get compliant, Voluntary Disclosure, but the program requires timely disclosure and full cooperation with the IRS in order to mitigate exposure to criminal prosecution. The process for willfully non-compliant taxpayers initially requires the taxpayer to obtain a pre-clearance from the IRS criminal investigation to determine whether the taxpayers is eligible. Upon receiving pre-clearance confirmation, the taxpayer is required to provide additional information. Needless to say, taxpayers judged to be willfully non-compliant must meet a difficult standard to get compliant. The potential penalties for these taxpayers include a civil fraud penalty that can be substantial. However, there are several items that are at the discretion of the examiners, providing willfully non-compliant taxpayers with an incentive to fully cooperate with the IRS and make restitution in a timely manner.
It is highly beneficial for a US person for tax purposes to seek the counsel of an international tax lawyer before using the procedure mentioned above. The IRS is dedicated to having taxpayers pay what they owe promptly and completely, and the rules and paperwork are complex and make people anxious. THEVOZ & Partners will evaluate each taxpayer’s situation and assist with IRS programs to be compliant with US tax laws.
THEVOZ & Partners has the knowledge and experience necessary to help its clients navigate streamlined compliance procedures by:
U.S. and Switzerland maintain close friendship and trade relations. Switzerland is known for its neutrality, legal clarity, and political stability. Besides, its top-notch financial infrastructure and beautiful mountains allow Switzerland to attract talent from all over the world. With offices in both U.S. and Switzerland, we can help our clients nagivate cross-border tax planning efficiently and professionally.
Within Cross Border Tax Planning, we specialize in:
U.S. Persons Operating Abroad
- Controlled Foreign Corporations
- Passive Foreign Investment Company
- Foreign Grantor Trust
- Foreign Gifts
Foreign Persons & Entities’ Activities in the U.S.
Within Tax Controversy, we specialize in:
Federal Tax Controversies
Internal Revenue Service (IRS) plans on hiring more employees. Many of these will be focused on ensuring that taxpayers are compliant. Whether in the form of the IRS’s Automated Under Reporter program (AUR), a correspondence examination, or an in-person audit, these employees are always reviewing and verifying tax filings. Guided by the extensive Internal Revenue Code and one of the largest workplace handbooks, the Internal Revenue Manual (IRM), these individuals have a wide variety of tools at their disposal. Anyone filing a return may be examined and subject to an audit and everything that comes with it. Dealing federal tax controversy requires an experienced attorney that can help navigate you through the complexities of the tax law and the intricacies of an examination by the IRS.
Let Thevoz & Partners stand by your side and fight for you. Don't face the IRS all alone because you do not have to. Our experts in tax controversy can provide both individuals and institutional clients with a knowledge, support, and experience to dispute a tax controversy. Working with a tax law professional can help you secure a more favorable outcome when dealing with matters involving the IRS.
Give us a call or contact us to let us assist you with your tax concerns at the federal, international, and cross-border level.
What is Tax Controversy?
Tax controversy is an area of litigation related to tax disputes between the U.S. Internal Revenue Service and taxpayers. Tax law attorneys provide legal services that any taxpayer can benefit from when it comes to audits or litigation. Controversies can either be civil or criminal. Civil controversies are by far the most common, but it is worth noting that civil cases can become criminal cases if a taxpayer is not careful or if the conduct was flagrant and criminal.
These professionals can also negotiate settlements on your behalf and resolve the case in the most efficient and least time consuming manner. Tax disputes can occur at the local, state, federal, and even international level. Individuals, businesses, corporations, trusts, and estates may all be subject to tax controversy. We have experience dealing with a range of issues including: second pillar accounts, unreported income, earned income tax credit, estate and gift tax (death tax), and itemized deductions, just to name a few. We can help you navigate a civil matter in an efficient way.
How THEVOZ & Partners Can Help?
The experienced and trustworthy tax law attorneys at our firm have years of experience in handling federal, cross-border, and international tax disputes. Through a collaboration of highly trained and motivated professionals, we can best assist individuals and businesses needing guidance in legal tax matters involving the IRS and other tax authorities by providing:
Our team offers you support through federal examinations, representing taxpayers and resolving tax disputes as efficiently as possible. In addition, we will represent you before the Office of Appeals. Through collaboration with local client service teams, we can manage tax controversies before they grow out of control. We will compile evidence and present your case in the best possible light.
Furthermore, there are three strong reasons why selecting a tax law attorney from THEVOZ & Partners would benefit you by:
THEVOZ & Partners specializes in the area of Tax Law
Within Relinquishment of US Nationality, we specialize in:
Expatriation and the dreaded “exit tax”
People renounce their US citizenship for a multitude of personal and financial reasons. But regardless of the underlying reason, all US taxpayers need to be aware of tax rules regarding citizenship renouncement. When you renounce your U.S. citizenship, you can be subject to an "exit tax", which is practically your final U.S. tax. Whether or not you are subject to an “exit tax” when renouncing your citizenship requires careful analysis and should be done in consultation with a professional. The rules vary depending on the taxpayers assets, income tax liabilities for the past 5 years, and their tax compliance. In addition, certain relief procedures may apply to your situation. For taxpayers that are “covered expatriates” it is important to discuss with an attorney whether there are any ways to minimize the exit tax and to ensure that assets are correctly valued. For taxpayers that are close to the line and may not be “covered expatriates” it is essential to document and value all your assets, preferably with qualified appraisers. And for those that know they are not “covered expatriates” it is prudent to ask your attorney if any relief procedures may apply to streamline the expatriation process.
Renouncing your US citizenship is a stressful decision that can be made easier with expert help. Navigating the immigration process can be daunting and the added level of tax compliance can make the process downright dreadful. But with professionals guiding you every step of the way the process can be handled effectively and efficiently. Do not let bureaucratic red tape stand in the way of your personal and financial goals. For more detailed information about expatriation, contact us today.
Controversy Experience
Our attorneys have litigated cases before the Tax Court and they can handle a case through every step in the process. Litigation may start with an audit but it does not end until collection. It is important to have attorneys that understand the complete process from start to finish so that they can get you the best result possible. It is also important to have attorneys that have an understanding of the tactics that the IRS uses to examine and collect from taxpayers.
Compliance
The US system has numerous information returns and failure to property file these can have adverse effects on taxpayers. For instance, failing to file information returns for foreign accounts can lead to penalties of 50% or greater on the high balance in the account. And many taxpayers are unaware that they may be responsible for filings FBARs on the accounts of their foreign businesses.
IRS offers several programs to help noncompliant taxpayers to become in compliance. Walking through these procedures alone can be daunting and even overwhelming. However, we believe that taxation should never get in the way of your personal and professional aspirations. That's why we are here to help. Let us deal with the messy details so that you can spend more time focusing on what really matters to you.
THEVOZ & Partners is fortunate to have an excellent and highly trained team.
