Income Tax Treaties
Title 26 – Internal Revenue Code
IRS Written Determinations*
Chief Counsel Advice*
Internal Revenue Manual*
IRS Forms and Publications*
*Not legally binding on the Service.
Client tips on hiring an attorney for offshore disclosure matters
Get Organized. If you’re paying hourly, then obviously good organization on your part will save you money. If your attorney is charging a fixed fee and does not sense that you are organized, you can expect that your fees might be higher to reflect the additional time commitment on the attorney’s part.
Do your Tax Research. Clients who have done their research understand the nuances and complexity of the work. Be prepared with good questions to gauge whether the attorney has handled cases like yours before. This may also prevent you from being overcharged for services.
Be Upfront During your Initial Consultation. This means truthfully and completely answering all questions, and proffering relevant information. It is important to identify any weaknesses so that they may be addressed early on, as well as to identify the full scope of the work involved.
Voluntary offshore disclosure firms to watch out for
Offshore compliance is a somewhat unusual area in tax law. It’s among the most complicated issues on individual tax returns.
We have clients nationwide and internationally. There are some common pitfalls to watch out for when selecting a firm to handle your disclosure.
BLOATED FLAT-FEE-ALL-INCLUSIVE QUOTES
It is not in the client’s best interests to pay legal fees for accounting work. In a “flat-fee-all-inclusive” structure, the hours involved in preparing tax returns are baked into the fixed fee.
Be careful. Many flat fee structures in streamlined cases are designed to benefit the attorney, not you. They will falsely tell you that if an attorney prepares a tax return, it will be attorney-client privileged.
Besides the cost issue, attorneys who have absolutely no accounting firm or previous tax return preparation background have no business preparing income tax returns. It is not a skill that is learned in law school, nor it is learned by taking exams. If you feel that you have been duped into a “flat-fee-all-inclusive” fee structure due to false or misleading claims about attorney-client privilege, reach out to your state’s bar for assistance.
There’s no such thing as a free lunch. When you get a free consultation, you get a sales pitch. We charge for consultations and for a good reason. A consultation should be professional, unbiased advice and not fear-mongering to scare you into hiring them.
A person does not have to licensed to handle tax matters, as the line between tax (accounting) work and tax (legal) work is blurred. So anyone can state that they practice “tax law” even though they never passed the bar. If you want to verify that your attorney is licensed, you can Google search “State bar of [enter attorney’s state] attorney lookup.” One of the first few search results should take you to the state bar’s attorney lookup page.