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IRS International Tax Controversy & Compliance

Taxpayers and tax professionals alike are often surprised by the myriad of IRS international information return requirements. While many of these requirements have been around for decades, the IRS has placed special focus on this area of compliance in the last 15 years.  

Matters involving foreign financial accounts and assets must be handled with special care since potential penalties often significantly outweigh the associated income tax consequences.  There are several potential solutions which depend on specifics of each case including the nature of the non-compliance, type of information returns involved and whether the IRS has engaged with the taxpayer.  Since certain options are only available before the IRS contacts you, please contact a qualified attorney as soon as possible if you have questions or believe you may be out of compliance.

For over 15 years, Mr. Jarski has handled numerous matters involving foreign financial assets and related international information returns.  Please contact us if you need additional information regarding any of the following:

  • Foreign Bank Account Report (FBAR) - FinCEN Form 114 requirement consulting and non-compliance correction

  • IRS international information return compliance including Forms 926, 3520, 3520-A, 5471, 5472,8621, 8858, 8865 and 8938 requirements consulting and non-compliance correction

  • IRS Criminal Investigation Voluntary Disclosure Practice

  • IRS Streamlined Compliance Procedures

  • IRS Delinquent FBAR Submission Procedures

  • IRS Delinquent International Information Return Submission Procedures


Special Areas

  • Forensic accounting involving large amount of data (foreign or domestic)

  • Passive Foreign Investment Company (PFIC) tax advice and calculations

  • Summary of foreign records to enable return preparation

IRS Domestic Civil Tax Controversy

Mr. Jarski handles a variety of domestic tax controversy  matters. Whether you are facing an IRS audit, collection action or you are looking to get back in compliance, we would be happy to help. Below are just some of the common cases with which we can assist.

  • IRS domestic voluntary disclosure practice

  • Non-filer representation

  • IRS collection matters

  • Penalty abatements

  • Installment agreements

  • Offer in compromise

  • Currently not collectible status

  • IRS audits/examinations

  • IRS Appeals

  • Refund claims

  • Employment tax matters

  • Trust fund recovery penalty (TFRP or IRC Sec. 6672) assessments

  • Domestic information return penalties

  • IRC Sec. 4980H Employer Shared Responsibility Provisions


In addition to the above, we can help with a variety of other tax related matters and questions; however, if we find another attorney or firm would be a better fit for your particular matter, we can often provide you with a referral.

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