Brotman Law Featured in Inc. Magazine - Fastest Growing Law Firm in California

FBAR Penalty Appeals and Compliance Programs

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Key Takeaways

  • Pre-assessment vs. Post-assessment
  • Litigation
  • Resolution Programs
  • Revised Offshore Voluntary Disclosure Program
  • Completing the Certification Forms

If you cannot come to an agreement to resolve your FBAR issue during the IRS examination stage, you may have a few options. The options available to you will depend on where you are in the penalty process, whether you were found to be in willful violation, and your history of compliance.

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Types of Foreign Income that Trigger Filing Requirements

Tax attorney consultation at Brotman Law

If you are a foreign business or person that does business with the U.S., then you are subject to U.S. income taxes. Some examples would be if your business has an office that generates income located in the U.S. or if a company owns rental property in the U.S. from which it derives income. 

Key Takeaways

  • Effectively Connected Income (ECI)
  • FDAP Income
  • Foreign Dividends, Service Income, Property Sales, Rents, and Other Income
  • Conclusion

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Brotman Law Featured in Inc. Magazine - Fastest Growing Law Firm in California