Tax Fairness for Americans Abroad Act of 2018! Let's get this passed!

Tax Fairness for Americans Abroad Act of 2018! Let's get this passed!

Tax Fairness for Americans Abroad Act of 2018! Let's get this passed! http://bit.ly/2EGkyuh Contact info for key players: http://bit.ly/2EDTmvh https://youtu.be/_WcK1vZtDh0 IRS Medic

Six Ways to avoid GILTI: How to beat the Global Intangible Low Tax Income

Six Ways to avoid GILTI: How to beat the Global Intangible Low Tax Income

Full article: https://ift.tt/2SSi675 What is GILTI: https://ift.tt/2MaYGHr GILTI help :There are six possible ways I know of to avoid, or perhaps more accurately, mitigate GILTI tax exposure. By this time, you probably know that GILTI stands for Global Intangible Low Tax Income. In previous videos I explained the rough idea of what GILTI is and in the next video of this series I will be discussing how to calculate GILTI liabilities. After calculating GILTI liabilities you may now realize how important this topics is. So be sure to subscribe so you don’t miss out on important topics. So now let’s get to those six ways. First, you can elect to covert GILTI to subpart F income. Now you might be scratching your head on this. If you understand a little about international taxation you know that Subpart F is something to be avoided. However GILTI can be so bad, that it can make Subpart F seem good! The second way is a little bit more opaque. You can increase something call QBAI. QBAI stands for Qualified Business Asset Investments. There are a few ways to do this. For instance one can purchase equipment that has been previously leased. The downside is that just because someone is a shareholder in a Controlled Foreign Corporation it does not mean that they can actually control the corporation enough in order to implement this strategy. Management might not be all that hip to this idea. And second, this is a business decision that could have negative effects to cash flow. You might solve a GILTI problem but you could end up with a business problem. Third, GILTI is NOT calculated on a company basis. It is done on a shareholder basis. And what’s worse is that losses in one CFC may not get full credit against gains of another CFC. The way to make sure you don’t miss out on any of your losses is by combining CFCs. Forth, simply avoid either CFC status or US shareholder status. The problem with this is tax reform expanded the definition of what it means to be have a CFC status. However, by adjusting ownership levels with non-US owners, you may be able to find a great solution that avoids this entire mess. The downside is this is not feasible for many people and second, you need to watch those attribution rules — which also have changed for the worse. When you have related parties, you might be considered to have CFC even though you would otherwise not if the parties were not related. The fifth way, and this is proving to be the winner for many of our clients, is to funnel all shares in foreign corporations into a domestic US holding company. This was an overriding theme of the 2017 Tax Cuts & Jobs Act — bring capital back to the US. The reason it works is that US C corporations are allowed to do something US individuals are not. Take what is known as a Section 250 deduction of 50% of GILTI. The downsides are that this does require extra hurdles of having a US domestic corporation which you must honor the corporate formalities of and an additional tax filing requirement of the domestic corporation. However, if your GILTI liabilities are even as low as say $20,000 or even $10,000, it still could be worth the hassle to create this structure. A sixth way I can think of is this. What about putting shares of a CFC into a Private Placement Life Insurance Policy or PPLI. PPLIs are used by the most sophisticated investors for what I consider to be the ultimate tax structure. Essentially how it works is that your assets go into a life insurance policy and you borrow from the death benefit while you are alive. And because death benefits are tax free, you’ve essential avoided all income taxes — both federal and state. This is an even better move to make if you happen to be in a high tax jurisdiction like California or New York. The downside is that life insurance turns most people off, and these are complicated structures and require a flexibility that so many business owners are unwilling to exercise. Additionally the costs are intense. Typically it only starts making sense when you have about $10 million in assets. We are woking on ways to reduce the cost, I’d love to hear from anyone who was able to implement a PPLI for for someone with less in assets. And also, I have yet to hear of a PPLI that has been implemented strictly with CFC stock. There are diversity requirements of a PPLI’s portfolio that could force you to sell your stock so much so that you could no longer have that CFC or US shareholder status. Also you must be very committed to following the structure. People get into trouble with PPLIs when they don’t take the rules seriously. Are there other ways you can think of to eliminate or mitigate GILTI? I’d love to hear about them. Please leave them in the comments below. Parent & Parent LLP 144 South Main Street Wallingford, CT 06492 (203) 269-6699 info@irsmedic.com https://youtu.be/teP8J5y13SM IRS Medic

International Tax Reform December 2018 Updates FATCA - TTFI - GILTI

International Tax Reform December 2018 Updates FATCA - TTFI - GILTI

MORE HERE: https://ift.tt/2G7uT3T Tax Reform 1.0, aka the Tax Cuts and Jobs Act of 2017 has some very unpleasant surprises for those with income and assets overseas. The good news is there is a stand alone bi-partisan legislation that will be presented for Congress to vote on and for President Trump to sign into law that will allow Americans living overseas to "opt-out" of the US tax code by simply filing a certificate that they are in compliance foe the past three years and now live outside the US. If this is passed into law, the burdens of compliance for the US exapt will be greatly reduced. In this video, Advocate for Americans Overseas, Keith Redmond and Attorney John Richardson of citizenshipsolutions.ca join tax attorney Anthony E. Parent as they discuss the proposed laws, regulations and potential law suit that could greatly help those frustrated by a tax regime that seems rather out of control. In particular the three discuss - An end to Citizenship-Based taxation and replacing it with a true territorial tax system - Potential relief for The Transition Tax (Section 965) and Global Intangible Low Tax Income (GILTI) along with the Foreign Account Tax Compliance Act (FATCA). - The IRS's offshore disclosure program for those with criminal exposure. While the acronym has stayed the same as OVDP, it now stands for Offshore Voluntary Disclosure Practice instead he prior Offshore Voluntary Disclosure Program. The three agree that very few expats should ever be scared into an OVDP and if a disclosure program is needed, a Streamlined Disclosure is far for preferential. Ultimately what is needed right now from everyone concerned is unity. No matter your political affilication, the law needs to be changed. The law fails to raise revenue effectively and it is just morally wrong to tax people who are tax residents of outher countries. It is essential that everyone contact Congress and makes their voices be heard: Territorial Tax for Individuals must pass! Parent & Parent LLP 144 South Main Street Wallingford, CT 06492 (203) 269-6699 info@irsmedic.com https://youtu.be/qa5jeq3hM1s IRS Medic

International Tax Reform December 2018 Updates FATCA - TTFI - GILTI

International Tax Reform December 2018 Updates FATCA - TTFI - GILTI

Tax Reform 1.0, aka the Tax Cuts and Jobs Act of 2017 has some very unpleasant surprises for those with income and assets overseas. The good news is there is a stand alone bi-partisan legislation that will be presented for Congress to vote on and for President Trump to sign into law that will allow Americans living overseas to "opt-out" of the US tax code by simply filing a certificate that they are in compliance foe the past three years and now live outside the US. If this is passed into law, the burdens of compliance for the US exapt will be greatly reduced. In this video, Advocate for Americans Overseas, Keith Redmond and Attorney John Richardson of citizenshipsolutions.ca join tax attorney Anthony E. Parent as they discuss the proposed laws, regulations and potential law suit that could greatly help those frustrated by a tax regime that seems rather out of control. In particular the three discuss - An end to Citizenship-Based taxation and replacing it with a true territorial tax system - Potential relief for The Transition Tax (Section 965) and Global Intangible Low Tax Income (GILTI) along with the Foreign Account Tax Compliance Act (FATCA). - The IRS's offshore disclosure program for those with criminal exposure. While the acronym has stayed the same as OVDP, it now stands for Offshore Voluntary Disclosure Practice instead he prior Offshore Voluntary Disclosure Program. The three agree that very few expats should ever be scared into an OVDP and if a disclosure program is needed, a Streamlined Disclosure is far for preferential. Ultimately what is needed right now from everyone concerned is unity. No matter your political affilication, the law needs to be changed. The law fails to raise revenue effectively and it is just morally wrong to tax people who are tax residents of outher countries. It is essential that everyone contact Congress and makes their voices be heard: Territorial Tax for Individuals must pass! Parent & Parent LLP 144 South Main Street Wallingford, CT 06492 (203) 269-6699 info@irsmedic.com https://youtu.be/y9J_stB9OWE IRS Medic

IRS announces new 2018 OVDP procedures - BIG UPDATE

IRS announces new 2018 OVDP procedures - BIG UPDATE

Contact: info@irsmedic.com Links: Article w/ text version of memorandum - https://ift.tt/2AzqxMS Upcoming CLE with Strafford - https://ift.tt/2TYEpZT On November 20, 2018, the IRS announced new Offshore Voluntary Disclosure procedures, ending months of speculation on what would happen without an official OVDP in place. Thanks to Jack Townsend for posting this notice on his Federal Tax Crime blog. https://youtu.be/HK5FscoYtao IRS Medic

Why are accounting and financial analysis so confusing?

Why are accounting and financial analysis so confusing?

Financial Statement Analysis and Accountancy 101: In this video we explain why you might not be such a dummy about understanding the basics and the more complicated items . Are you frustrated by accounting and financial statements? If you are given a balance sheet, do you just want to run and hide? Are you intimidated by P&Ls, accruals, amortization, double-entry bookkeeping? Good news. I'm not going to get too deep into any of that. But rather, I want to share with you my own frustrations with accounting and financial statements so that you can completely dispel the notion that understanding accounting and conducting your own financial analysis is somehow above your abilities. 1. There are no black and white answers. Accounting is supposed to reflect reality. Yet reality is an awfully complicated sort of thing, isn’t it? And also, sometimes people want to show you a particular kind of story. For instance, can you ethically manipulate your books to show a high value so that you can obtain optimum financing? The answer is yes. It’s done all the time. And conversely, could you show lower profits, hence a lower value, to reduce your taxes? Yes, and this too, is done all the time. In fact, both things are done so routinely, no one even mentions it. Yet there exists this idea that “numbers are the numbers” and “numbers don’t lie.” What complete nonsense. Numbers can be the most effective lies! The dirty secret about accounting is that everything is cooked. But as long as you understand the underlying assumptions and the purpose of the books, and how they were “cooked” the books can still be both honest and helpful. 2. If you are more confused after speaking with either your attorney or accountant or CFO something is wrong. If you are able to start or run your own company, a good attorney, accountant, or CFO should be able to explain any concept to you in simple language. 3. Trust your gut. No one should ever be more interested in your business than you. You probably know the right answer, you are just unable to express it in accounting terms. But just because you can’t express it, doesn’t mean that you’re not right. 4. If you can measure something you can improve it. This is a critical function of accounting. This is why it is so important to understand the underlying assumptions that are “cooked” into the books — then you can make meaningful comparisons to see how you are improving and what still needs improving. Bottom line: Your books should work for you, not the other way around. But sometimes a business owner needs help getting their books to work for them. For us, we’ve seen very little difference between a great accountant and a great lawyer and a great CFO. As a tax and business attorney, I actually speak the same language as our accountants and ou clients' CFOs. All of us work in concert to characterize and qualify things in order to better represent a narrative that suits our clients needs the best. So what do you find confusing about accounting? We’d love to see if there is actually a question we can’t answer in 100 words or less. So please, if you have a question, leave them in the comments below. We love a challenge. Parent & Parent LLP 144 South Main Street Wallingford, CT 06492 (203) 269-6699 info@irsmedic.com https://ift.tt/1RfwK1f https://youtu.be/IGm9GoFEEhk IRS Medic

Why does the IRS audit taxpayers? This insider information that might really help you

Why does the IRS audit taxpayers? This insider information that might really help you

Does this seem like a silly question? Well it's not. Because slowly but surely, the IRS audit process has changed over the last 10 years and it is critical you understand why, if you or your business is the one who is the subject of an IRS examination. In this video, tax attorney Anthony Parent speaks about both the public statements the IRS has made, along with his law firm's clinical experience helping thousands of taxpayers deal with an overbearing IRS. While so many articles are written by tax lawyers, accountants, CPAs and other tax professionals about the IRS Audit Red Flags, Attorney Parent explains the reasons why these articles are obsolete. Believe it or not, the IRS used to audit, or in IRS-speak “examine,” every single taxpayer. The reason is that when the income tax was first enacted in 1913, it only applied to those who were truly wealthy. No income tax was due until your income exceeded an inflation adjusted $500,000. And the top tax rate of 6% did not come into play until your income was at the equivalent of $12 million. Because the income tax affected so few people, the IRS had the resources to audit every single return. This changed of course. When Congress blatantly and openly broke the central promise of income tax by applying the tax to nearly everyone — not just the truly wealthy as promised. This drastic change created a flood of new taxpayers that the IRS audit team could not keep up with. So the IRS began to audit only a portion of taxpayers year after year. The purpose of these audits was to primarily ensure compliance. Believe it or not, assessing additional revenue was not the main goal of the examination division. Again, it was compliance compliance compliance. So anyone could be subject to an audit. The IRS really wanted to spread the misery around, and it did. Along with multibillion dollar corporations the IRS would also routinely audit the plumber down the street. But things changed politically. The IRS is one of the least-liked organizations in the world. And many politicians don’t want to be seen as supporting the IRS. Yet, they don’t want that revenue the income tax brings in to dry up. So what’s the play for someone who needs to look like they are on the taxpayers side, but are still completely in love with that revenue the IRS brings in? Well it’s simple. Cut the IRS’s budget. In fact, the IRS’s budget has been cut so much, in the last ten years, the IRS lost its most experienced agents and officers. Yet they haven’t been replaced. Yet, Congress insists the IRS do more with less. And because ensuring compliance isn’t really a goal that has a data points that one can rest their conclusions upon, the new focus for the IRS examination divisions has become something that is more measurable — that is, increased assessments. So this is the sea change. The IRS is no longer interested in compliance for compliance sake, but rather wants examinations where there will be a good chance of assessing additional taxes and for them, massive penalties. So what types of cases involve the prospect of huge additional assessments? The focused targets we see are: Domestic cases where the IRS suspects something egregious; Cases involving foreign income and assets. The IRS wants domestic audits where they suspect a slam dunk that could trigger massive civil fraud penalties along with a huge tax assessment. And also, the IRS also wants more international audits. The reason? Cases involving international income and assets are a huge penalty wonderland for the IRS. There exists a litany of penalties that can trip up any decent, honest, intelligent person. Penalties of over $10,000 for not reporting the existence of a foreign bank account on what is known as an FBAR form, and penalties of $10,000 for not reporting the ownership of a foreign bank account on a slightly different form, a Form 8938 Along with: A $10,000 for not reporting interest in a foreign business on Form 5471 A $10,000 for not reporting a Foreign pension on Form 3520-A A $10,000 penalty for not reporting distributions from a foreign pension on a Form 3520. A $10,000 penalty for not reporting a transfer to a foreign business on Form 926. Multiple penalties for multiple years can really add up into the hundreds of thousands of dollars. Oh and by the way, this list is far from exhaustive. And willful FBAR penalties can even be higher How to win your audit? It is critical you get the highest level of legal representation possible if you are worried that a revenue-hungry examiner is looking at you as a mere target to aggregate into a press release. Parent & Parent LLP 144 South Main Street Wallingford, CT 06492 (203) 269-6699 info@irsmedic.com https;//www.irsmedic.com https://youtu.be/FxVRnJnegMQ IRS Medic

IRS OVDP ended September 28, 2018. What are your options now?

IRS OVDP ended September 28, 2018. What are your options now?

IRS ends OVDP — what to do if you missed the deadline The IRS ended its Offshore Voluntary Disclosure Program or OVDP for short, on September 28, 2018. So what does this mean for taxpayers who have not made a disclosure? What should they do now? Are there any options left? In this video, I’ll explain exactly what paths remain open for those worried about FBAR penalties, the myriad foreign reporting penalties, and criminal prosecution. First thing: Good news, most people don’t need the full OVDP Since June of 2014 when relaxed streamlined disclosure rules were announced, thousands of taxpayers from every corner of the globe have called into our office quite sure they must use the standard OVDP and pay that 27.5% or 50% penalty that the program calls for. But after we talk to most people, we find that the streamlined program is more far appropriate for them. The benefit of the Streamlined program is there is a 0% or 5% penalty and only three year look back for unpaid taxes. So not only is the tax and penalty bill lower, but so to your attorney and tax preparation bill. It’s why we really like the Streamlined program. Which by the way, is still open. The problem is that taxpayers have a difficult time assessing their risk profile. What we find is that the people who should be scared to death of a criminal prosecution often aren’t. Meanwhile taxpayers who are convinced they will be going to prison tomorrow actually have a small risk of prosecution. What program is best for you is really something you need to talk to an experienced tax disclosure attorney about. Additionally, many taxpayers don’t even need a Streamlined disclosure. So many of them are able to just file delinquent forms to solve their problem. Second thing: A voluntary disclosure program MUST ALWAYS EXIST and there is nothing the IRS can do about it. Congress actually mandates that the IRS always have a voluntary disclosure program. So you might be confused. How can the IRS end the OVDP if this is true? The reason is that that the OVDP is a specific type of Voluntary Disclosure. Voluntary Disclosures existed long before 2009, which marked the first Offshore Voluntary Disclosure Initiative and these disclosures were primarily used to protect against unreported domestic income. For instance let’s suppose a taxpayer owns a regional US pizza chain and intentionally did not report sales that were paid in cash. And now he is worried that someone may whistle blow and he could be subject to a tax evasion indictment. Well that person, even though they have no foreign income or assets to report could still get in the standard Voluntary Disclosure program. So for domestic tax evasion, you would use the plain old Voluntary Disclosure program. If international tax evasion was involved, you were forced to use the OVDP. So now with the OVDP gone, the only type of Voluntary Disclosure is left is the plain old non-specific Voluntary Disclosure. You still might be a little confused so let me try to explain more. The OVDP was a combination that offers (1) the standard voluntary disclosure protections from criminal prosecution, along (2) w a pre-determined offshore penalty scheme of either 27.5.% or 50% of asset base. So really the only thing that ended September 28th is this second item. There is no longer that pre-determined offshore penalty scheme. However, you can still get protections from criminal prosecution by getting into the plain old Voluntary Disclosure program. So its wonderful that you can still get protections from criminal prosecution. But what about protections from massive FBAR and foreign informational return penalties? Unfortunately, with the OVDP penalty scheme now gone, each taxpayer making a that plain old Voluntary Disclosure will likely be subject to an IRS examination. The IRS examination is where FBAR and Foreign informational return penalties may or may not be assessed depending on how well your facts and circumstances are developed. The goods news is that the standard of review for such an audit is very much akin to the OVDP opt-out standard, which has delivered some remarkable success for many of our clients. Their OVDP opt-out penalties were much lower than the standard OVDP penalty that they though they would have to pay. Parent & Parent LLP 144 South Main Street Wallingford, CT 06492 (203) 269-6699 info@irsmedic.com https://youtu.be/g9oI7lCbEMg IRS Medic

Should you be nice to the IRS?

Should you be nice to the IRS?

https://ift.tt/1RfwK1f Tax lawyer Anthony Parent of Parent & Parent LLP helps answer this question. The IRS is a scary, dense organization. The IRS has powers you wouldn’t believe, yet communicates in a way that is often indecipherable. Yet it is critical you understand what the IRS is saying — as if you get something wrong, the IRS can levy bank accounts, garnish any payments to you, file a tax lien —- all without a court order. So with these constraints, it is at all possible to be nice to the IRS? Would you be better off being mean and nasty to them? You might think that by chewing out the IRS, you can get them to back off and be reasonable. You might think that by finding the biggest pit bull of an attorney, that will put the IRS in its place. Well does it? I think I can answer this question by answering a different question: Are there any strategic advantages to being nice to the IRS? Let me illustrate the difference. Over 10 years ago, I was at an IRS conference sitting next to a CPA whose had an office down the street from ours. He was bragging to me about how awesome he was. He might have been hitting the wine a little hard too. We were both sitting at the same table. He was showing me letters and emails he sent to IRS agents. So he proceeded to tell me the he enjoyed working overtime to humiliate and annoy all the revenue agents and officers he ran into. He really seemed to be impressed by himself. He was a force to be reckoned with, don’t you know? Afterwards, I asked some of my friends in the IRS what they thought of this CPA. The consensus was something like “Yeah we know he’s a jerk. Too bad his clients don’t know he is ineffective.” Here’s the thing. We tend to be nice. Some of it was bound to happen. My first partner, my father, David G. Parent, worked in state and municipal agencies for decades — he was a government bureaucrat. And myself, I applied for a job as a revenue officer in 1997. So my dad and I never looked at IRS employees “as others.” We thought, you know they could be us? So intuitively, we were also nice to the IRS. We treated them as we want to be treated. And what has this niceness done? As much as I rail on the unfairness, inappropriateness, and the injustice of the US income tax, it would be completely dishonest for me to say that IRS employees are bad. In fact, some of them have been the greatest friends to us imaginable. Below are four quotes from IRS employees who were speaking to us about various cases. While we did not necessarily get the exact thing we were looking for, we did get the overall relief our clients were seeking. “Anthony I can't let your client win on the statute of limitations issue as local counsel won’t sign off on it. But what I will do is put your client into a hardship status where in 5 months they can win on the statute of limitations issue.” This saved my clients thousands in legal fees and a complete disaster at home. If we were nasty, would this IRS appeals officer hand us this unconventional win? “Anthony, if you just get me proof your client is trying to sell their vacant property I’ll push this through. I don’t care what my manager says. I’ll take the heat.” this was a quote from a revenue officer stuck his neck out to help us save our clients’ home and business. If we were jerks, would he have stuck his neck out? “Sorry, your client filed their tax court petition a day late. I can’t do anything about that. But here, why not go to the taxpayer advocate? I bet your client has a better chance getting that employee classification they with them rather than with the tax court anyway.” This was a quote from an IRS attorney. And he was right. We ultimately won and our client saved $480,000. “We were investigating your client for tax evasion and FBAR violations. But seeing how he’s hired your firm, as long as you follow your compliance plan, we will move on to someone else.” This is a quote from a Department of Justice attorney. He saved our client from a criminal indictment and millions in taxes and penalties, restitution, along with the brutal humiliation of an indictment. In all four cases, we got help from the people that were supposed to be against us. I think a reason why is that these IRS and Department of Justice employees saw our clients as real people. Government employees, while perhaps biased, are not inherently bad at all. Their goodness can seep out despite the government’s best wishes. The thing is you have to give them room to do so — niceness helps create that space. Parent & Parent LLP 144 South Main Street Wallingford, CT 06492 (203) 269-6699 info@irsmedic.com https://youtu.be/RTbZlPGCe7U IRS Medic

Warning to Green Card Holders/Permanent Residents - top US tax questions answered

Warning to Green Card Holders/Permanent Residents - top US tax questions answered

Once you possess a Green Card, you are now taxed on your worldwide income just like any US citizen would be. Additionally, other reporting requirements may exist. For instance if you have overseas bank accounts in excess of $10,000 you likely have an FBAR or what is also know as a FinCEN Form 114 requirement or you could face up to a 50% penalty on account value. Additionally, there exists a litany of foreign reporting forms, like Form 8938, Form 5471 for example that Green Card holders have an obligation to file at a rate much higher than the public at large. Failure to file the forms starts a $10,000 per year and can get as high as $50,000 per year. Again, these are risks that can all be managed. They just take some thought and effort. https://ift.tt/2OQ5tro What is the income tax rate for US Green Card holders? The income tax scheme for US Green Card holders is the same as it is for an American citizens. Taxation is exactly the same. There are no increased or decreased tax rates for Green Card holders. But as we show, their issues tend to be more complicated and the income tax tends to be more onerous because of the types of overseas and foreign investments Green Card holders often possess. What are the tax filing requirements for US Green Card holders? US Green Card holders have the same filing requirements as US citizens. Green Card holders overseas, like US citizens abroad, have an extended time to file taxes, usually June 15th which can be extended to October 15th, and then there is a permissive extension until December 15th. What is a US Green Card holder responsible for when filing? For all tax filings, taxpayers are ultimately responsible for everything they sign even if they can’t understand what they are signing. Additionally, even if they could fully understand English, that is slight guarantee that they know what they are signing as the IRS tax code is so expansive it is unknowable any one person. Are there any tax benefits to being a US Green Card holder? Only if you think that being taxed as a US citizen is a benefit. Can you deduct the cost of your obtaining your Green Card on your tax return? Some may advise against deducting the legal fees relating to the acquisition of your Green Card, but it is not an entirely unreasonable position. What are the tax consequences of allowing a US Green Card to expire? The Green Card is evidence of your Permanent Residence status, but it is not the thing that actually grants Permanent Residence status.  Just because your Green Card expired does not mean you are a no longer subject to US taxation. Yes, this is true even if you are overseas and not eligible for re-entry. It is possible for the IRS to tax you even though the federal government won’t let you back into the United States Your obligation to file and pay U.S. taxes as a long term green card holder persists until there is a judicial or administrative order, or alternatively, until you file Form I-407. A lapsed green card on its own does not terminate your IRS tax obligations. What are the tax consequences when surrendering a US Green Card? Have you had a Green Card for 8 or fewer years of the last 15? If so, then great. You can surrender a Green Card without triggering any exit or departure tax. If however you have been in the US for more than 8 of the last 15 years, and your assets exceed $2 million you may want to engage with our firm to legally lower this exit tax. What is the departure, expatriation, or exit tax for US Green Card holders? For those who have been in the US long enough and have the assets to trigger an exit tax, IRS Form 8854 is used. If I leave the United States without surrendering my Green Card, and without paying or filing the exit tax return, what can the IRS really do to me? Enforcing the US tax code against people who are not in the US and do not have property in the US or any reason to return to the US is incredibly difficult, but not impossible. Some countries have joint agreements to cooperate with the IRS. Many people have gone this route, and truth be told, have gotten away with it. The problem is if another opportunity arises that makes US presence necessary. For instance, many ex-Green Card Holders will return to the US on a investor visa if their children go to school in the US or start a family within a US.  Leaving a loose end like an improper exit tax, or none at all, could very much complicate or completely frustrate a return to the United States. If I try to enter the US with a green card or a passport from another country, will I have a problem if I am in tax non-compliance? You very well could have a problem. Parent & Parent LLP 144 South Main Street Wallingford, CT 06492 (203) 269-6699 info@irsmedic.com https://ift.tt/1RfwK1f https://youtu.be/gNOb3_wYNW0 IRS Medic

PFICs and IRS Form 8621 Assessments: Tech Talk

PFICs and IRS Form 8621 Assessments: Tech Talk

Congratulations to tax attorneys Robert S. Schwartz & Elizabeth C. Petite on a great win! The Tax Court's recent decision in Roberto Toso and Marcela Salman v. Commissioner US Tax Court, Dkt. 8324-15 151 TC ___ No. 4, September 4, 2018 sheds some light on two aspects of reporting foreign income from Passive Foreign Investment Companies to the IRS. The first item is that the IRS got hoisted by its own process. PFIC income does not necessarily change AGI, but rather Form 8621 calculates income and then imposes the highest marginal rate to create a tax due, then this tax due goes on a tax return AFTER adjusted gross income is calculated, along with interest.. Meaning, not all unreported PFIC income is subject to the substantial understatement rule that can open a tax return for an additional 3 years of audit. Also, the Tax Court ruled, in a believed-case of first impression, that the HIRE Act only applies to foreign informational returns that were open when the HIRE Act was signed into law. Meaning, if a foreign information return assessment statute ASED) was closed in 2010, the HIRE Act does not open it. However, post-2010, any unfiled foreign informational return (Form 8938, Form 5471, Form 5472, Form 8865, Form 8858, Form 926, Form 3520, Form 3520-A) can keep an assessment open indefinitely. Yet, a proper disclosure can close those open years, even if there was unreported income. Parent & Parent LLP 144 South Main Street Wallingford, CT 06492 (203) 269-6699 info@irsmedic.com https://youtu.be/0qawBZUpn5Q IRS Medic

Tax traps of holding and attempting to renounce a US Green Card

Tax traps of holding and attempting to renounce a US Green Card

Joining us today is a special guest, Gary Clueit. Mr. Clueit is a US Green Card holder who has been in the US for 34 years. He employs hundreds of people, but the US tax code is forcing him into a precarious situation. Helping to clear the confusion is John Richardson of Citizenship Solutions, Keith Redmond, global advocate for the American Overseas, with host, tax attorney Anthony Parent of Parent & Parent LLP The four discuss the problems unique to sophisticated Green Card holders like Mr Clueitt, who have investments and business around the world. The problem for Green Card holders is that once they have held a Green Card for 8 of the past 15 years, they are subject to an exit tax. Doubling insulting is that their US assets, after renouncing, after paying taxes on them, is subject to the estate/inheritance tax of US property owned by a foreign person. Which is what someone like Mr. Clueit becomes once he surrenders his Green Card. There are some possible solutions, but would they work for Mr. Clueit? And as Mr. Clueit recognizes he is fortunate enough to have the resources to tackle his IRS issue. The fact is that many don't have or can't see the wisdom in paying six figures or more for a compliance and planning package. The fact is that the US tax code, and additions like the Foreign Account Tax Compliance act has not just made Americans toxic, but too, America toxic. Mr. Clueit speaks of market changes in the tech sector have made it so that America is not a must-go-to destination for those advancing their careers, but the additional problem of a terrible taxing regime is absolutely harming America's competitiveness. Unfortunately, it does not look like Tax Reform 2.0, if passed, will offer much relief to Green Card holders like Gary, but rather, must look to innovative lawyers and tax professionals to make the best of a bad situation. Again, Mr. Clueit can afford this cost, but many others can not. Parent & Parent LLP 144 South Main Street Wallingford, CT 06492 (203) 269-6699 info@irsmedic.com https://youtu.be/uLY36oDGjqo IRS Medic

Is the tax premise to Happy Gilmore plausible?

Is the tax premise to Happy Gilmore plausible?

Happy Gilmore is a delightful coming-of-age story of a young aspiring hockey player, who possesses a great slap shot, but not much else, aside from his uncontrollable rage, as he struggles with a forced career change due to his grandmother’s impending seizure of her home and belongings due to $270,000 in unpaid taxes to IRS. As a tax attorney, the question I’m always asked is “is the tax premise to Happy Gilmore at all plausible?” I am happy to report that the answer is yes. My joy comes from the fact that most Hollywood writers get tax issues all wrong. In this video, I will explain why this premise works, get into some technical nitpicking, but also, show how it is possible for grandma to keep her house and get the IRS to leave her alone through a little known strategy. Happy Gilmore was released in 1996. And the way the IRS worked back then was much MORE aggressive. So aggressive that a couple years later The Reform and Restructuring Act of 1998 was passed to reign in the IRS’s abusive collections practices. How bad did the IRS get? IRS revenue officers would seize someone’s home not for $270,000 but sometimes when the taxpayers owed less than $5000! So here’s some things we know or will assume Grandma owes $270,000 She owns her house outright. The home is worth $450,000 Grandma only gets social security and not much else. Grandma is 80 years old. So with these facts, could you make the IRS go away? Yes. The key is the old part. Grandma is old.  Remember that? That means whatever she has is all she will have. She’s not getting a lucrative job tomorrow.  While a $450,000 house is nice, it represents the entirety of grandma’s wealth. So one solution would be a hardship status with the IRS. Submit financials proving a limited ability to pay. The IRS will simply not do anything, aside from intercept refunds, if any. Now what will happen is the IRS will file a lien on the property. Meaning that once grandma dies, the lien attaches and the IRS will come in between Happy and his grandma’s estate. Happy is only entitled to proceeds after the IRS is satisfied in full. Which is why I don’t like this solution as much. I want an Offer in Compromise. And this is this the entire key to the case: how to legally eliminate grandma’s equity in her house -- as the IRS will want to start offer in compromise negotiations as-is with 80% of Fair market value of her house. Other things we must avoid is a fraudulent conveyance or something that would deemed dissipated asset, which would happen if she signed the house over to Happy without a resolution in place. There are two ways to do get rid of her equity in her house that I can think of.  One is through a reverse mortgage, the other is to sell the house for fair market value, take back a life estate along with an annuity. With either the reverse mortgage or annuity, Grandma would have more income each month (remember she got into tax trouble because she ran out of money.) But these additional proceeds aren’t enough to make her rich, or increase her tax burden in any substantial way. Her increased income would still likely be below the threshold in which the IRS finds any collection potential, thus the IRS would be very interested in accepting less than the full amount owed with a carefully constructed offer in compromise. Now some of you might wonder, how did Grandma get her house back after Happy's chief rival, Shooter McGavin bought the house at the auction? The answer is that in most circumstances there exists a right to redemption, where the foreclosed party just needs to match the highest price to keep the house. I would imagine that Grandma would have 30 days after the auction in which to redeem. The writers got this part right too. So before you abandon your fledgling minor league hockey career to help your grandmother out of a financial tight spot by utilizing your bizarrely awesome golf ball driving skills to become a golf champion, get an opinion from a tax attorney to see if such a bold move is necessary. While drama makes for compelling entertainment, don’t you think that drama in the real world is just a bunch of work that someone else should really be doing? Parent & Parent LLP 144 South Main Street Wallingford, CT 06492 (203) 269-6699 info@irsmedic.com https://ift.tt/1RfwK1f https://youtu.be/oQtF0W4NCUY IRS Medic

How long should you keep tax records? IRS.gov has some great traps to fall into

How long should you keep tax records? IRS.gov has some great traps to fall into

How long should you keep your tax records? The IRS website has a page that claims to answer this question: https://ift.tt/29AWo1g But how accurate is this information? Are there things the IRS forgets to mention? Is there advice the IRS gives that could lead to disaster? Watch this video to the end to find out things that perhaps the IRS doesn’t want you to know. For most people they can get rid of their tax records after three years. Why? In most cases, the IRS is really only allowed to audit the last three years. For instance, right now it is 2018. In 2018, 99% of the examinations the IRS commences are for tax years 2015-2017. But many of you might have heard about the rule that says you need to retain your records for 7 years. So where did that number come from? the answer is that the IRS has a few exceptions to its three-year look-back period. If you understate your income by more than 25%, the IRS can go back an additional 3 years for a total of 6 years. But that’s sort of an interesting paradox. How does the IRS know you understated your income by 25%? Wouldn’t an auditor have to conduct an examination to know that you did that? And this is why we see so few audits that get opened for six years. The IRS needs to have some credible information you understated your income by 25% through some verifiable source before that audit begins. What’s the most common way this happens? Taxpayers and their representatives don’t organize their files correctly when under audit and just dump too much data on an auditors desk which includes information on years outside the 3-year period the auditor was examining. The Fraud exception Another exception is if you file a fraudulent return, the IRS can examine and assess indefinitely. So the IRS advises you to keep your tax records indefinitely if you file a fraudulent return. Which I suppose makes sense from the IRS’s perspective. But let me tell you a story that demonstrates how this advice helps the government, not taxpayers. Real Estate and property The IRS correctly advises that if you have property you should hang on to all your records for as long as you own the property plus the typical three years thereafter. Yet, we encountered a case where this rule would have resulted in a $40,000 tax bill to a client had he followed the IRS’s advice. Some big misses - FBAR recordkeeping The Report of Foreign Bank Accounts, or FBAR, is a US Treasury form that is administered by the IRS. For decades the form was ignored by the IRS. This however was changed in 2009, when the IRS realized it could use the threat of ruinous FBAR penalties — up to 50% of account value — to cajole people into the first Offshore Voluntary Disclosure Initiative. So there is a failure to file penalty for FBARs, yet there is also a penalty for failing to keep records. You must keep records on all foreign bank accounts for 5 years. The fact that this information is missing on irs.gov is understandable — the IRS has a lot on its plate. But it is also unforgivable. Because the IRS is rather obstinate about finding that someone had reasonable cause and is entitled to an FBAR penalty waiver. It is unforgivable as the IRS is fine taking 50% of someones assets for this FBAR record-keeping oversight. But it is the same exact oversight that IRS.gov makes. It fails to mention the 5 year record retention requirement on this record retention web page. So why are we holding taxpayers to a higher standard of care than the IRS? What about if you were audited? The IRS does not mention this, as this advice would probably help you, not them. If you are ever audited, you might want to hang on to those audit records forever. Why? Because you may be audited later and you may be raising a claim that the IRS was previously OK with or due to their bad advice helped contribute to. The foreign assets and income trap Speaking of Form 5471, which is a type of foreign informational return for US shareholders of a foreign corporation to file. Well there are a litany of other foreign informational returns. And they all have the same problem. These other forms include: Forms 926 Form 3520 Form 3520-A, Form 5472 Form 8621 Form 8858 Form 8865 Form 8938 The problem is this. If the IRS deems you to have filed a substantially incomplete foreign informational return, the IRS can open your entire tax return, no matter how old it is to a complete and full examination. So in fact, the IRS’s entire web page dedicated to record retention become wholly obsolete if foreign informational returns are involved. Parent & Parent LLP 144 South Main Street Wallingford, CT 06492 (203) 269-6699 info@irsmedic.com https://ift.tt/1RfwK1f https://youtu.be/M6NOA67V06Q IRS Medic

Saving US Citizenship Act: Expats should have to renounce because of the IRS

Saving US Citizenship Act: Expats should have to renounce because of the IRS

FATCA & Citizenship-Based Taxation makes US lives impossible overseas. Joining us today is Mark, a US expat in Switzerland who is on the cusp of renouncing US citizenship. He's got a great story -- US expats aren't "others," they could be any US citizen who took a temporary assignment at work -- because that's Mark's story: How a temporary overseas assignment can lead you you and your entire family US citizenship. Anne was born in Oklahoma, Mark was born in Texas. The two met in Louisiana and they married in 1985. They had a son in 1988. Mark was a star employee and was offered a temporary relocation to Geneva Switzerland in 1999 when his company consolidated operations. They had a daughter in 2000. The dot com bubble saw all of Mark friends in the US lose their job. So what supposed to be a temporary, stated to look more permanent — they had a great life in Switzerland, meanwhile had they stayed in the US, things would have been a lot worse for them. In 2006, they realize that the US tax laws are a bit terrible to comply with. They thought about going back to the US, but Mark had no prospects, so they kept living a great life. And the hopes of going back to the US were further dashed by the economic collapse in 2008 - there were no positions to be had in the US. Also, the two realized that their children have only known Switzerland. Moving back to the US would not be easy. However, as Democrats, the two were optimistic that a new president, Barack Obama would impose a better tax treatment for expatriates. However, these hopes were dashed after a a Democrats Abroad meeting in 2010, which we chaired by future vice-presidential nominee, Tim Kaine. A fellow attendee brought up what was then just a proposed law, the Foreign Account Tax Compliance Act (FATCA) and that it posed a huge danger for expats. The FATCA discussion was tabled for healthcare reform talk much to the chagrin of the audience. Why was FATCA necessary? What would FATCA do? Would it be as bad as this one attendee claimed? These questions would be answered in 2013 when their Swiss bank quarantined their accounts because they are US persons. They allowed their mortgage and checking account to be active, but nothing else. In 2014, Mark was offered a relocation to Germany but declined. One reason is that they would realize a gain on their home they would not be able pay the taxes on, and second they fully realized that their children were more Swiss, than American. They were fully integrated in Geneva. This is their life. In 2015, Mark tried self-employment, but he found as an American, he was not wanted. He overhead HR professionals remark that Americans are more trouble than they are worth thank to FATCA. the stress the FATCA was causing was intense. He developed stenosis of the esophagus from the inescapable stress In 2016, his son facing extreme humiliation as he was US person who is shut out of the banking system. His son wanted to renounce. Mark convinced his son to wait out until the tax reform package was signed. After seeing the true territorial system was not passed Mark’s entire family renounced US citizenship by 2018. Joining Mark and Attorney Parent is Keith Redmond, and John Richardson. Keith and John have been instrumental working on reform and give their key insights to the process and landscape. Keith announced that the new Territorial Tax For Individuals bill will be call the Saving US Citizenship Act - which is a brilliant and accurate name. Parent & Parent LLP 144 South Main Street. Wallingford, CT 06492 (203) 269-6699 info@irsmedic.com https://ift.tt/1RfwK1f Keith What is going in in Europe TTFI news Saving US Citizenship bill https://youtu.be/5Tns2dfWUnw IRS Medic

Expat Ryan Socash v. the IRS - How FATCA Repeal gained another powerful advocate

Expat Ryan Socash v. the IRS - How FATCA Repeal gained another powerful advocate

You don't have to be a US expat as YouTube famous as Ryan Socash to have an issue with the IRS. In this video, tax attorney Anthony Parent interviews Ryan one-on-one to learn how Ryan discovered he had a huge problem and the reasons why he decided to disclose to the IRS with the Streamlined disclosure program. Ryan Socash was born in America, but found his home belonged in Poland. There, he has been overseeing a growing media empire, including his own personal YouTube channel, Kult America, https://www.youtube.com/KultAmerica/ Ryan describes how he felt when he learned about the Foreign Account Tax Compliance Act (FATCA) when he received his first FATCA letter from a Polish bank. FATCA lead him to research to discover the odd way the US taxes its citizens who are tax residents of other countries. FATCA led him to discover the host of scary international tax problems including: - Unfiled FBARs - Missing Form 8938 - Missing Form 5471 While many US expats have decided to stay out of the US tax system and avoid coming clean at all, that was simply not an option for Ryan as his personal belief system won't allow him to not follow a law he is aware of. But with that said, now Ryan is a a full-blown repeal FATCA advocate and is helping to see that this awful law that makes life difficult is repealed. Parent & Parent LLP 144 South Main Street Wallingford, CT 06492 (203) 269-6699 info@irsmedic.com https://ift.tt/1RfwK1f https://youtu.be/9g3Qlqdt_Dk IRS Medic

Territorial Tax for Individuals (TTFI) update/live event August 16, 2018

Territorial Tax for Individuals (TTFI) update/live event August 16, 2018

Are you in Toronto August 16th? Don't miss this important AmCham event with Solomon Yue of Republicans Overseas. You can add your input on how you think tax reform should treat US persons who don't live in the US. Link here: https://ift.tt/2OBC57M Joining Tax Attorney Anthony Parent of Parent & Parent LLP is John Richardson of citizenshipsolutions.ca and Keith Redmond, Global advocate for the Americans overseas. In this podcast we discuss the differences between Citizenship Based Taxation (CBT)/Universal Tax Jurisdiction and a territorial system. We explain how tax reform created a territorial system for corporations, but not for individuals and our work that change that. Thanks to the great work a tireless advocates, Representative George Holding (R-SC) will introduce a stand-alone TTFI bill we hope in late August early September 2018. Should this pass, this would be a monumental achievement. The taxing jurisdiction of the United States has not been changed since Tait v Cook, a 1924 US Supreme Court case. To get engaged and help the cause, join American Expatriate 2.0 on facebook or now on Linked in: https://ift.tt/2nAbZ9Q for updates: https://ift.tt/2OBC6bQ https://ift.tt/2vDQV6L Parent & Parent LLP 144 South Main Street Wallingford, CT 06492 (203) 269-6699 info@irsmedic.com https://youtu.be/Y8laRRtc000 IRS Medic

I haven't filed taxes in 30 years! (It's not as fun as you think)

I haven't filed taxes in 30 years! (It's not as fun as you think)

As a tax attorney, it is common for me to encounter people who didn’t do things correctly. And I recall this one time, I met a stone mason from Norwalk, Connecticut who confided with me that he hadn’t filed taxes since the Reagan administration. How can this happen? How can someone not file taxes in 3 years, 5 years, 10 years, 20 years and in this case, 30 years? The answer is easy. You’ll do it tomorrow. And after you’ve had about 10958 tomorrows that adds up to 30 years. Procrastination is incredibly easy to achieve, but sort of difficult to live with. Will you go to prison for years of unfiled tax returns? Anytime you are breaking federal law, you are really increasing your chances of prosecution. The US Department of Justice will prosecute those with unfiled returns, but the chances are that they won’t, unless you are doing something else or you are just too big of a fish to ignore. Now a big fish isn’t necessarily that big of a fish. For the IRS, a press release is what they want. If you’ve made $100,000 for the last 10 years, and are unfiled, you are definitely getting into the area of a big fish — the IRS can truthfully say in a press release, you did not report over a million dollars of income. And for the average juror and the public at large, there is little difference between a million and a billion. Of course there’s a huge difference, a million is a thousand thousands, and a billion is a thousand millions. Regardless, the perception can be that you’ve been living the high life, all while not paying taxes nearly everyone else is paying. But even if you do come under investigation, there is always something you can do to protect yourself. File your returns ASAP! I don’t understand this paralysis that comes over people once they are under criminal investigation. These should be the people working the hardest and quickest to get a problem behind them. But instead they are often advised to “sit back” and “wait” to see what happens. Well I am pretty sure I know what could happen if you don’t fix a huge problem that you know that you can be indicted for. Hint: It rhymes with indictment. Wait. No. The word is indictment. Why you SHOULD NOT File ALL Your Unfiled IRS Tax Returns. How many years should I go back? You will see different answers to this question. Because here is the inherent tension. Filing fewer returns could create criminal or audit exposure, filing too many can slow down resolution and you can wind up paying more than you should have. Some will give blanket rules, filing three, six, ten, or even back to the beginning. We look at each case one at a time. While the IRS’s policy is six years back, there are times when following this rule can create more problems than it solves. We’ve done more, we’ve done less. This is really an area where getting a professional opinion could save you a lot of money and headache. Refunds rule benefit the IRS If you don’t file a return, the IRS could assess you for those taxes at any time in the future. Our stone mason with that 1985 return? The IRS could file a SFR for him today! And would add in penalties and interest. However, if you are owed a refund, you have a limited amount of time file a return to claim that refund. The general rule is that you must file your refund claim three years from when the return was due - extensions count, or two years since a payment that you seek a refund on. If you are a day late, you will likely be completely frustrated from claiming a refund. The US government will keep your money even though they know you can prove you are owed that money. 100%. The IRS can assess forever, but when you are owed money, you have a small window of opportunity. Does this sound fair? Tax attorneys for tax problems Parent & Parent LLP 144 South Main Street Wallingford, CT 06492 (203) 269-6699 info@irsmedic.com https://ift.tt/1RfwK1f https://youtu.be/7ckPfYcjFnM IRS Medic

GILTI income - Freqeuntly asked questions and answers

GILTI income - Freqeuntly asked questions and answers

GILTI stands for Global Intangible Low-Taxed Income, and it is just awful. https://ift.tt/2MaYGHr GILTI was created in Section 951A of the US tax code by the 2017 Tax Reform. It involves incredibly complicated calculations and huge additional compliance burdens starting for tax year 2018, and for certain types of shareholders in foreign corporations, can dramatically increase taxes. Why was GILTI passed? Wasn’t tax reform supposed to make taxes simpler? Tax Reform was sold as a simplification of the US tax code. And for US taxpayers with simpler returns, their tax filings did become simpler. However, for those with interests in corporations overseas, compliance got more complicated. The purpose of the law was to discourage something called “base erosion.” Base erosion is basically profit shifting from something that is US taxable to something that is not taxable by the US. IRS GILTI changes the definition of what your tax base is, making it larger, thus subject to immediate taxes, as opposed to being able to defer taxes until a later date. Wasn’t tax reform supposed to create a territorial tax system? A quasi and limited territorial tax jurisdiction was created by Tax Reform. Certain active businesses are able to take advantage of this partial territorial tax system. For other businesses who have passive income or are structured differently can be negatively impacted by this very unhelpful portion of tax reform. The IRS has been real serious about another type of base erosion method, claimed abusive transfer price manipulation for years. In a way, GILTI is an expansion. https://ift.tt/2y8cco9 Who is affected by GILTI? US Shareholders in foreign corporation that have a lot of a passive income will be hit the hardest. For instance, if your a company has a lot of income from patent royalties that used to be US-tax deferrable, GILTI could affect you significantly. What are the GILTI tax rates? GILTI creates no additional tax rates. What it does is expand the definition of what is taxable. Controlled foreign corporation shareholders, or CFC for short, must now include with their currently taxable Subpart F income their share of the CFC’s deemed intangible income return for the tax year. Now — beware tax reform expanded CFC definition — there is possible CFC status anytime there is a U.S. shareholder of a foreign corporation anywhere in the group. The new law ends prior deferral treatment and subjects “U.S. shareholders” of CFCs, defined as U.S. persons owning at least 10% of the vote or value of a specified foreign corporation, to current tax on any income more than 10% of the CFC’s qualified business asset investment (QBAI). What this means is that GILTI will hit tech companies, service providers and firms with a high degree of intangible assets particularly hard. Are there ways to lower GILTI taxes? Most likely. Parent & Parent LLP 144 South Main Street Wallingford, CT 06492 (203) 269-6699 info@irsmedic.com https://ift.tt/1RfwK1f https://youtu.be/n1cN9SSbs34 IRS Medic

Tax Reform, Form 5471 & foreign-owned US subsidaries -- navigating the mess

Tax Reform, Form 5471 & foreign-owned US subsidaries -- navigating the mess

https://ift.tt/2LJaB2m Tax reform made it so that 100% non-US owned US subsidiaries now have to file a Form 5471 for any non-US subsidiaries that there foreign parent owns. This sentence is no doubt, incredibly confusing. This video may help you understand how much of a dramatic change this is and creates huge burdens on foreign companies doing business in the US. In 1960, Congress passed the first law that required corporations and individuals to self-report extensively on their US controlled foreign corporations. The purpose was to reduce the ability of US taxpayers from “playing games.” The law made it so that the IRS can look at everything a US taxpayer- controlled corporation is doing overseas, to make sure their overall worldwide income was properly assessed and taxed. Self-reporting is completed on an IRS Form 5471. IRS Form 5471 is quite intense. And unfortunately the same burdens apply if you are a large multinational corporation or if your foreign corporations are not quite as large and closely held. With complicated instructions, the Form requires you to know which category of filer you are to determine which schedules you need to file. The IRS requires you to convert the accounting method you use overseas over to GAAP. The US is the only country in the world that uses GAAP and all Form 5471 filed with the IRS must comport to GAAP or else..the penalties. The penalties for not filing or filing a substantially incomplete Form 5471 start at $10,000 per year and can reach $50,000. Additionally, if a Form 5471 is not filed, the statute of limitations on the Form 5471 is indefinite. So who has to file a Form 5471? If you are a US shareholder in US controlled foreign corporation you have a Form 5471 requirement and must attach it to your return. But also, tax reform made is so non-US means US! Tax Reformed changed what it means to be a US controlled foreign corporation. For every other similar subsidiary around the world. the US foreign owned subisdary probably has a Form 5471 requirement. Causing further concern is the IRS has made Form 5471 penalties a pretty significant part of it enforcement regime. These penalties are easy to assess and can boost up assessments, making the IRS audit divisions look good to Congress and the Treasury Inspector General. So how did this happen? Downward attribution is what the term is used to justify turning a non-US controlled corporation into a US controlled corporation. If you are confused great! It means you are paying attention. Because downward attribution makes about as much sense as “wet roads causing rain.” Downward attribution is a way get something to mean exactly what it doesn’t mean. So why? First I don’t think anyone who voted for this knew what they were voting on. This rule came into place because a section of tax code was removed by tax reform, not added. The justification for this rule is the same argument from my first example. A US subsidiary could be playing games with transfer pricing, allocating income and expenses to lower US subsidiaries tax bill. Therefore, the argument goes, a Form 5471 is required so that IRS could track both or all sides of every transaction with every related party to the subsidiary. But I wonder. Does this onerous compliance regime actually help the US? Here’s the thing. International tax compliance is so difficult the IRS does not have the staff to actually administer it effectively. Two main reasons. One it takes a long time. A very long time. Second, it actually takes a pretty special person to be able to understand the complexities. Whether you are talking about a tax professional representing you or IRS employee tasked to examine you, one both sides, it takes elite talent to properly work an Form 5471 case. The fact is tax reform made international tax compliance far more complicated. If you or your company needs help in navigating not just the old minefields, but these fresh new minefields, don’t hesitate to contact us to see how we can help you get your compliance worries behind you. So what do you think? Do you think it is a good idea the the US government puts such a burden on international business? Do you think there’s a benefit that outweighs the cost? I love to know what you think and if want you would like in the next tax reform package. Parent & Parent LLP 144 South Main Street Wallingford, CT 06492 (203) 269-6699 info@irsmedic.com https://ift.tt/1RfwK1f https://youtu.be/dIwYRSo3mHw IRS Medic

FATCA Repeal Update: The action to take right now!

FATCA Repeal Update: The action to take right now!

Act by August 8, 2018 https://ift.tt/2mJo3oL Join Anthony E. Parent, Esq., Keith Redmond, John Richardson and Suzanne Herman for a very important message about a second repeal FATCA hearing and how you can help make this happen! ATTENTION AMERICANS OVERSEAS! There is a SERIOUS bi-partisan push for an updated FATCA hearing to address the sharing of personal financial data and the lock-out of Americans overseas from foreign financial institutions (i.e. their local banks). As a result of Suzanne Iclef Herman's hard work and tenacity in establishing and cultivating a relationship with her Congressman and his staff, we have succeeded in building bi-partisan momentum in an updated FATCA hearing. Suzanne requested to Congressman Posey’s office that I get involved in order to have as many Americans overseas as possible contact their respective Congressmen/Congresswomen. The attached letter has been sent to Members of Congress (MOC) in a bi-partisan effort to have the House Ways & Means Committee hold another FATCA hearing. In conjunction with the request, MOCs have been sent a letter (in the same aforementioned attachment) which each MOC can send to House Ways & Means Committee showing their support for another hearing. Americans overseas are asked to write their Congressmen/Congresswomen to sign the letter. Go to https://ift.tt/2mJo3oL to fidn the exact steps you need to take to help with the repeal of the FATCA Parent & Parent LLP 114 South Main St Wallingford, CT 06492 (203) 269-6699 info@irsmedic.com https://youtu.be/Kvk0Cqt5ZM0 IRS Medic

Are IRS passport revocations & denials at all Constitutional?

Are IRS passport revocations & denials at all Constitutional?

https://ift.tt/2LDV5RO Is it constitutional for the IRS to revoke your passport? The government can now deny or revoke your passport for unpaid taxes. Does this sound at all Constitutional to you? If your passport can be taken away for unpaid taxes, what’s next? Will the government take away your voting rights? You right to own a firearm? In this video I am going to talk about a truly horrendous law that should concern everyone and what you should do if you are worried about losing your passport to unpaid taxes. The FAST Act of 2015 allows the IRS to direct the US state department to deny or revoke your US passport. When I first saw this, I couldn’t believe it passed. On the practical aspect, I know that the IRS and the State Department have enough work to do, and that this law will just burden them even more. But on an intellectual and moral level, this law just bugs me every which way. Why? Because while l know a US passport is technically the property of the US government, the US Supreme Court has ruled that the right to travel, even across borders is a fundamental right. A fundamental right. Meaning the right to travel is up there with freedom of speech, freedom of association, freedom of conscious. Fundamental. Rights do not get anymore important than fundamental. Now this is not to say the government can’t restrict or inhibit fundamental rights. The government can. It does all the time. But in order to do so, the government must provide due process which includes the right to be notified and the right to an impartial hearing. One of the problems with the passport revocation law is that the only notice comes though mail. And what’s worse, is the IRS admits that it has a difficult time getting mail to US persons overseas - all who likely have a US passport. Do you think a letter that you may or may not receive is proper notice before revoking a fundamental right? In additional, when impacting a fundamental right, the Supreme Court says legislation must pass the “Strict Scrutiny” standard of review. The highest level of review. To pass strict scrutiny, the legislation must further a compelling governmental interest, and also must have been narrowly tailored to achieve that interest. And this is where Congress loses me. I get that collecting revenue and ensuring compliance with tax laws is a compelling state interest. But how is taking away someone’s passport narrowly tailored to ensuring compliance with tax laws? There just can’t be some attenuated or indirect connection between the law and the desired outcome. But rather, the law must be narrowly tailored. Or to put it another way, how would be infringing on the fundamental right to travel be any different than other denial of other fundamental rights? It gets more obnoxious when you realize that the IRS was already the most powerful collection agency in the world. The IRS can levy, garnish, and file liens all without a court order! Why aren’t these narrowly tailored tools good enough? It is because the IRS isn’t using them to the fullest extent? Actually that is true. The IRS is so short staffed it can’t do the normal collections they used to do 10 years ago. So instead of funding the IRS to the appropriate level, Congress pulls this crap. Creating headaches for taxpayers, the IRS, the state department and my prediction, there will be no meaningful increase in revenues. Now would a constitutional argument prevail? The strongest argument I see is the lack of procedural due process. You simply should not be able to invalidate a fundamental right by mail, especially when you know mail is quite unreliable. And that impartial hearing in front of a judge is missing too. With IRS passport revocations, the only hearing you are entitled to, if you are not too late, is in front on an IRS Appeals Officer. And while I think this law should not pass strict scrutiny, the fact is the federal government is greedy for revenue and will bend over backwards to validate anything called a revenue bill — even if it fails to raise revenue. However, to win on a claim I would estimate about $150-300,000 in lawyer fees and the case might take years to resolve. In the meantime, the government takes your passport. That’s why I suggest if you have back taxes and you are worried about losing your passport contact us about our passport protection services. Our mantra is that every situation can be made better. So why not have one less thing to worry about. Parent & Parent LLP 144 South Main Street Wallingford, CT 06492 (203) 269-6699 info@irsmedic.com https://ift.tt/1RfwK1f https://youtu.be/LiTa3HWqeIY IRS Medic

Can you use wash sales to offset cryptocurrency gains? Probably

Can you use wash sales to offset cryptocurrency gains? Probably

If you invest in stocks, securities or cryptocurrencies such a Bitcoin and Ethereum, this is an important video to watch. Many have made mistakes for not understanding what a wash sale is and when it is prohibited by the IRS. You might not know this term. So I will explain what is use using a real stock. Let say you bought 1000 shares Starbucks (SBUX) @$60 per share on December 13 2017 for $60,000. On July 1, 2018, you see that the stock has dropped to $48 per share. Meaning you had a loss of $12,000. You have some other stocks that have done well, so you are looking for a way to lower your taxes. You think to yourself — hey you know what would be a good idea? Can you use your SBUX stock to realize a loss and then immediately buy it back to maintain my position? Sounds like a solid plan, right? Sounds like it should work. Can you think of any problems? Well this is where having some knowledge of the tax code would really help. This is what is technically known as a “wash sale” Wash sales are prohibited by Section 1091 of the Internal Revenue Code. Section 1091 states that your need a 30-day lag between selling and buying back otherwise, the loss that occurred will not be deductible. Now because it is a 30 day lag on both ends, you actually have to wait 61 days before buying a stock back in order to be able to claim your loss. Otherwise you will lose again. Once on the decrease in the value in stock and again, when the IRS won’t give you credit for the loss you actually suffered. So can you use wash sales to utilize cryptocurrency losses? Cryptocurrencies are bit volatile and because of this, many US taxpayers have large gains. But sometimes they are sitting on huge losses as well. The question is can you sell off the cryptos that have lost value to apply those losses against gains in order to lower your tax bill? And also, can you then immediately buy those cryptos back to maintain your market position? The answer is probably yes, section 1091 does NOT apply to cryptocurrencies. Will the IRS change its mind? Probably. There’s money to be had. Of course, the IRS can always change this rule. Section 1091 does allow the IRS to expand the “stock or securities” that trigger the wash sale rule. If the IRS passes a regulation clarifying that Bitcoin and other cryptocurrencies do fall under the jurisdiction of Section 1091, wash sales may be disallowed. It’s safe to assume that the IRS will eventually take the step to disallow wash sales of virtual currency. Personal property v. intangible property Yet, its conceivable that the tax treatment for cryptocurrency can get worse. For example, one unfavorable outcomes would be that the IRS could make the decision to treat cryptocurrency as personal-use property as opposed to intangible property. Capital losses from the sale of personal–use property, such as your home or car, are not deductible. See IRS Publication 523. Parent & Parent LLP 144 South Main Street Wallingford, CT 06492 (203) 269-6699 info@irsmedic.com https://ift.tt/1RfwK1f https://youtu.be/tWP772YAiY4 IRS Medic

FATCA Failure: The Top 10 reasons why the Foreign Account Tax Compliance Act is just awful.

FATCA Failure: The Top 10 reasons why the Foreign Account Tax Compliance Act is just awful.

TIGTA's report shows $380 million was spent for the IRS to (partially) implement the Foreign Account Tax Compliance Act (FATCA) meanwhile the revenue that FATCA was claimed to bring in never happened. In this video, we discuss the tope 10 reason why FATCA is one of the worst laws ever to pass, as it costs the government more money to implement, meanwhile making lives for Americans painful, if not impossible. The TIGTA Report: https://ift.tt/2zrxUJ1 The Top Ten Reasons why FATCA is a failure It was passed on an accounting lie. This PAYGO lie. PAYGO stands for “pay as you go budgeting” and it is supposed to keep spending bills deficit neutral. In this case, the HIRE Act of 2010 was a spending bill, so offsets needed to be found. The claims was FATCA would find about an extra billion dollars or so per year in revenue. And so how as that works out? According to professor William Byrnes and Robert Munro at Texas A&M, the revenue is not there. What you’ll see is a red herring from the government. The claim that thanks to FATCA, $10 billion in penalties collection as part of the OVDI, OVDP and streamlined programs. These were one-time payments only. But for the most part those are attributable to enforcement of the Bank Secrecy Act’s FBAR requirements, not FATCA. So why the revenue is not there, the costs certainly are. This brings us to Number 2. TIGTA puts the cost at $380 million so far. And there’s lot more work the IRS has to do to get FATCA fully implemented. 3. Risky. The government cannot provide any reliable assurance that the private financial information obtained on millions of U.S. and non-U.S. persons can be in any meaningful sense be considered secure. Imagine a data breach here. Lots of sensitive information there. What if say Turkey or Iran was looking for info on dissidents? What if they got info on someone whereabouts because of FATCA. What if that person was assassinated? 4. The cowardice of nations. Every one seems to talk tough about standing up the the US. So why couldn’t they find some courage to tell the US to get lost with FATCA? kind of sad the US bullied other countries, kind of sad that all these countries acquiesced to the bullying. They may have done so thinking that they’d get something in return. But they haven’t FATCA has been one-way sharing of information too the US. 5. Compliance vultures. This law benefits no one except those in the FATCA compliance industry. And for them, FATCA has gold. It’s been good for billions of dollars per year. 6. What was left of the 4th amendment was shredded. There exists no right to privacy. The IRS is entitled to your financial information even when there is no income to report. 7. The tribalism and dysfunction of our political system. One party passed FATCA. Another party wants to repeal it. You would figure those harmed by FATCA would be on the side of the party that wants to repeal it. But I have seen too much tribalism at play. Trashing people who you want to help you is kind of …stupid. Also, by telegraphing you will vote for the party that passed FATCA NO MATTER WHAT well…you just indicated to them that they can ignore you without any fear of consequences. If you can’t vote for for the party that wants to repeal FATCA, fine. But you don’t have to say that out loud. Make the people that doesn’t want to repeal FATCA second guess themselves. Make them think you could switch parties and never come back. 8. Triplicative reporting. So you could have a bank account that needs to be reported on an FBAR form. And a Foreign Financial Institution may be reporting this account the the US. Yet you still have to report this account again on a Form 8938 or face a possible $10,000 penalty, even though the account may actually make no income of which taxes could be due. With the Bank Secrecy Act and FATCA, three times the government learns of a foreign account. And as we learned form TIGTA report, the IRS is flooded with so much data, FATCA can’t be fully implemented. 9. The drain on IRS resources. FATCA imposed more burdens on an already understaffed IRS. This meant the IRS had to pull resources away from other areas. There is a reason why when you call the IRS for help hold times are long. There is a reason why a lien release that used to take 5 days now can take 5 weeks. There is a reason why claims for refunds take much longer. 10. Forced expatriation of US persons. This is the worst. A US citizen should have the most opportunity in the world. FATCA made that impossible. In order to continue to live their lives overseas, many Americans from retirees to US armed services veterans have had to give up their US citizenship to survive. Parent & Parent LLP 144 South Main Street Wallingford, CT 06492 (203) 269-6699 info@irsmedic.com https://youtu.be/5BqO9cbyr-E IRS Medic

The terror behind IRS Private Debt Collections: Who is really to blame?

The terror behind IRS Private Debt Collections: Who is really to blame?

The answer? It NOT the IRS that is to blame It is Congress. We try to be fair to the IRS, and in this case, the IRS got it right. They were the ones who we more fair and humane. It is Congress that rather monstrously passed this dumb dumb dumb idea. Private debt collection is something the IRS once experimented with, but it quickly realized it was a bad idea. Between 2006 and 2009, with Congressional approval, the IRS tried on their own using private debt collectors to try to collect taxes on cases that were too small to send to revenue officers or otherwise weren’t getting worked. The IRS ended this experiment realizing there was no free money. The program created more headaches than it was worth. As the IRS learned that there was a reason why these cases were uncollectable. The people they went after were dead broke. So the IRS abandoned the idea of using third party private debt collections forever and would stick to their normal collection processes that do have some important protections available for those who are financially struggling. Legislative accounting fraud is enabled by something called PAYGO budgeting. PAYGO budgeting, which stands for “pay-as-you-go,” it is a budget rule which requires new proposed spending to be offset by tax increases or cuts in mandatory spending. What this means is that if Congress wants to spend $100 on a new spending program, it has to find $100 in cuts or in additional revenues. The purpose is to keep the budget deficit low. Yet the budget deficit continues to grow. So what’s going on? The answer is that while the spending is sure to happen, the offsets, the cuts or increases in revenue rarely occur. Yet, just because those offsets never happen, the spending is not undone. No rather, nothing is done at all. it is all swept under the rug. So how does PAYGO apply in this case? Let me explain. So in 2015, there was a new proposal — this was the FAST Act, a new spending bill. And so Congress was looking around for some offsets. So someone had the idea that if only past due IRS debts were sent to private collection, it would rain free money. About a billion dollars of unpaid taxes where there just for the taking. Free money! This claim was completely accepted as true, again even though, again, the IRS tried a limited private collection program and it completely failed. Again, it failed so bad the IRS stopped doing it. Yet the program actually cost $13 million. The IRS spent $20 million dollars so far to administer the program, but it only brought in $7 million in revenue. That is, the deficit increased by $13 million. So instead of not offsetting the spending like PAYGO demands, it actually increased the deficit. But what is even worse is when you ask yourself where did that $7 million they did collect come from? These taxpayers were deemed to be the lowest priority of IRS collections. How did these seriously strapped individuals come up with $7 million. Well the Taxpayer Advocate Service did some great research. And it found that these taxpayers, if using IRS guidelines would have been placed in a hardship status. A hardship status is where the IRS deems you to be currently not collectible. So they leave you alone, although they will intercept any refunds that you may be entitled to. Under the IRS guidelines these people would not be subject to levies or the threat of levies. Yet many of these people have been sent out for private collections! So in an effort to make themselves appear as fiscal hawks, Congress mandated that private collection agencies extract money from the most vulnerable Americans, making these suffering people more vulnerable. Look I know my firm and a lot of the other good ones would be able to get tax relief for anyone facing a financial hardship. But so many people simply don’t have the resources to pay us even if we charged half our fees. It’s only the lucky ones who have friends or family to borrow from or get a gift from that get the top representation. There are legal clinics and they are great, but there’s simply not enough of them, and they are typically bound to the school year as most of them are run out of law schools. Yet here we are, Congress authorized private debt collectors to extract money from Americans who not just below the poverty line, which for a married couple is about $16,000 per year. But, according to the Taxpayer Advocate, many of the people the government collected from made less than 2 1/2 times of the poverty line. We are talking about is people who have $5000 per year to live on. Let me know what you think and what kind of solutions you would impose. I will merely offer my observation — tar and feathers always seem to work. We just got to make sure we get the right people. And in this case, it is NOT the IRS. Parent & Parent LLP 114 South Main Street Wallingford, CT 06492 (203) 269-6699 https://youtu.be/qXESF_j5BKE IRS Medic

Are cryptocurrencies currency or property? The US Treasury can't decide.

Are cryptocurrencies currency or property? The US Treasury can't decide.

Are cryptocurrencies property or currency? It’s a great question – I wish that I was able to give you clear guidance on what the United States government considers it to be. But, I can’t – and I’m a Tax Attorney. It’s not that I don’t know what the rules are. I know the rules better than most. But, I am hit with an immediate conflict that i want to share with you. That’s legal term – virtual currency. I’m throwing that term out to you for a reason. That’s a term that FinCEN (Financial Crimes Enforcement network, a division of the US Treasury) calls cryptos. Why? So that it can apply the rules of the Bank Secrecy Act to cryptocurrency. If it were to be property, the argument would that the BSA could not apply and FinCEN would be powerless to regulate. Now, consider this -- the Bank Secrecy Act was written by Congress in 1970 – requiring financial institutions in the United States to assist U.S. government agencies to detect and prevent money laundering. Bitcoin was created in 2008. So, FinCEN is using 48-year-old legislation to regulate a modern technology – to regulate cryptocurrency exchanges like banks. Even though cryptos are not banks. Not at all. Now The IRS – another division within the United States Treasury – has announced that it considers virtual currency as property. So for purposes of regulating transactions under the BSA, the government considers cryptocurrency to be currency. But, on the other hand crypto currency is to be viewed as property for federal tax purposes and applies tax principles applicable to property transactions. In other words, the IRS wants to be sure is doesn’t miss out on crypto gains it could tax and FinCEN wants to regulate cryptos, hence we are left with conflicting rules. The way that the regulation is currently imposed has caused cryptocurrency to lose the utility that it was originally intended to have. I don’t want to get into whether this is a good or bad thing. But, because most of the exchanges are in compliance with the Bank Secrecy Act – the original utility of anonymity has been destroyed. Maybe you’re ok with that – maybe you’re not. But, it’s irrefutable that the tax policy is designed to discourage the use of virtual currency from being used as it as originally intended – as currency. In order to be in compliance, the cryptocurrency user has to report every transaction he makes. In other words, the cryptocurrency user can’t walk into a cool hipster coffee shop and use cryptocurrency to buy a cup of coffee without having to calculate the capital gain or loss on the transaction. Now, this at first may seem like a minor inconvenience. But, in order to do this accurately the user needs to be able to specify the particular units of bitcoin to be used in the transaction – not exactly as practical as handing cash over the counter to the barista. It’s no wonder that certain studies report that 59% of Americans don’t report appropriate cryptocurrency-based capital gains to the IRS. I have a feeling that figure is much much higher. As of right now, in 2018, the government is applying a limited regulatory structure to cryptocurrency. Nonetheless, the government is applying an antiquated regulatory structure to cryptocurrency. It’s to be expected. The folks working within the United States Treasury are dealing with a new technology neither the BSA or the Income tax ever contemplated. Of course they are not going to be about to come up with a cohesive rule. In their defense, even the most astute regulators didn’t expect the rapid increase in the valuation of cryptocurrencies. Nor did they expect Wall Street to express such interest in investing and speculating on cryptocurrencies. So now it’s the duty of the people in the communities surrounding cryptocurrency to make their opinions known about what to do about the regulatory puzzle surrounding cryptocurrency. For regulatory purposes, should cryptocurrency be viewed as currency or property? Now confusing matters is that all currency is technically property but not all property is currency. But how should a regulatory framework be designed for cryptocurrency? Should government have any involvement at all? What should we do about the current conflicting interpretations by FinCEN and the IRS? Parent & Parent LLP 144 South Main Street Wallingford, CT 06492 (203) 269-6699 info@irsmedic.com https://youtu.be/sBj4Hqy0XQE IRS Medic

Can you cheat the FBAR? What happens if you don't file?

Can you cheat the FBAR? What happens if you don't file?

Here are some things you really should know before you decide NOT to file an FBAR. The FBAR is the Report of Foreign Bank Accounts. FBAR is also known as FinCEN Form 114. A person or entity is required to file an FBAR if they have a financial interest in or signature authority over at least one type of foreign financial account that exceeds an aggregate value of $10,000 at any time during the year. FBAR reporting is not limited to foreign bank accounts. Pensions, life insurance policies, and accounts that earn no money have to be reported. The FBAR form is a complicated form and is viewed by some as an invasion of privacy. Some clients ask whether they can get away with not filing an FBAR form. I advise those clients that FBAR penalties are steep and willful non-compliance is illegal. Therefore, to avoid legal consequences, I advise filing an FBAR form. There are six things to be aware of before not filing an FBAR. If you ever filed an FBAR, you are now in the FinCEN database. Once you are in a database, you can be tracked. People who don’t comply with the reporting obligation and don’t risk consequences are people who don’t get caught. The IRS only needs to catch you once. IRS tax examiners will ask a person about FBARs. If a person doesn’t answer honestly, he will face civil and criminal penalties. However, answering honestly will have consequences too. Failing to learn about foreign account reporting requirements can be evidence of “willful blindness.” See Internal Revenue Manual, 4.26.16.4.5.3, Paragraph 6. The DOJ also investigates people for criminal charges related to FBAR non-compliance. Criminal penalties for FBAR violations are frightening, including a fine of $250,000 and 5 years of imprisonment. If the FBAR violation occurs while violating another law the penalties are increased to $500,000 in fines and/or 10 years of imprisonment. People who have grievances against you are often very willing to offer testimony to the government. If you are not going to file an FBAR form, be confident that the people aware of your reporting obligation won’t offer testimony to the government. Income and assets can be attached to pay outstanding FBAR penalties. If you have no income or assets that can be attached, you may be able to avoid collection. However, in some jurisdictions, the IRS may be able to seize part of your spouse’s assets to pay your bill.   The statute of limitations for FBAR penalties is 6 years. However, after six years, the IRS may still be able to penalize you for other unfiled foreign reporting forms like Form 5471 or Form 8938. These penalties can be assessed for multiple years, and unlike FBARs, there is no statute of limitations on these types of penalties. A person’s best option is to file an FBAR correctly and get into a proper offshore disclosure plan. However, there are three things to consider that may take the sting away from this compliance regime:   The FBAR intel is low value to the government. By filing an FBAR, you’re merely bogging down government bureaucracy. There is no such thing as an FBAR initiated audit. No one looks at an FBAR unless a tax audit is initiated. Don’t think that filing an FBAR is a red flag to get you audited. If you are going to “come clean” with the IRS do it right or don’t do it at all. Lying to the IRS will make things worse. https://ift.tt/2kQWHfk Parent & Parent LLP 144 South Main Street Wallingford, CT 06492 (203) 269-6699 info@irsmedic.com https://ift.tt/1RfwK1f https://youtu.be/11rv3eh9f0k IRS Medic