We minimize your taxes domestically and internationally...
VIACHESLAV S. KUTUZOV
International and U.S. Taxation Expert, admitted to practice before the IRS (No.00144810-EA)
New York Licensed Legal Consultant
55 Broadway, 4th floor, New York, New York 10006
We apply international standards of confidentiality
ISO / IEC 27001 Information security management
© Viacheslav Kutuzov LLC, 2017. All rights reserved.
Tax Planning for Individual and Corporate Clients
We reshape the role of tax in your life...
In the United States, taxes are the major expenditure of both businesses and individuals. In some instances, the tax burden may be a crucial factor for concluding a contract, opening a new branch, launching a new product or making another important business decision. On the other hand, an unexpected tax bill may undermine the current budget and impede obtaining many public licenses and permits. This concern is actual regardless of the size of the business or the industry. Even professional financial consultancies may have to litigate tax authorities decisions on their actions.
Effective minimization of tax liability is impossible without thorough tax planning. Formally, tax planning is a proactive form of modeling positions on a tax returns. In fact, it is a method of projecting financial results, budget control, and eventually, establishing wealth and prosperity. Despite the great number of technicalities, tax planning still may not be fully automatized, remaining the product of the human professionalism. As a segment tax industry, tax planning constantly undergoes legislative and standardizing changes. That is why it is utterly important to follow major trends.
We provide our clients with the personalized short- and long-term tax planning solutions in form of a detailed a roadmap of financial, administrative and managerial transformations, which aimed at optimizing their finances both domestically and overseas. Scrutinizing every line of the tax return and business plan, we may offer our clients the most balanced and reliable ways of overall tax burden minimization or deferring the current tax liability. We are specialized in double taxation minimization under U.S. international tax treaties.
Our practice is based on the ten strategies of tax minimization.
What we actually do:
Besides tax planning, we advise our clients on simplification, streamlining, and securing of the data collection and management processes. With our assistance our clients may redesign, redefine and redeploy tax to be a strategic asset across the enterprise.
Tax Returns and Disclosure
The obligation to file tax returns depends on many factors, including the amount of taxable income, tax residency, and sorts of taxable activities. We will examine all those factors and choose the correct methods of reporting. Our office provides professional services of preparation and filing all types of tax returns for corporate clients and individuals.
Also, the U.S. law contains numerous disclosure requirements. American taxpayers have to disclose foreign financial assets, such as bank accounts, brokerage accounts and mutual funds (so-called FBAR disclosure). Certain U.S. citizens and residents who are officers, directors, or shareholders in certain foreign corporations file Form 5471 and schedules to satisfy the reporting requirements of sections 6038 and 6046, and the related regulations. A 25% foreign-owned U.S. corporation (including a foreign-owned U.S. disregarded entity (DE)), or a foreign corporation engaged in a trade or business within the United States may have to file form 5472 to disclose foreign ownership and/or reportable transactions. Failure to comply with disclosure requirements normally results in severe penalties.
Our team offers thorough professional assistance in filing all types of disclosure report, developing disclosure protocols and policies, assessing and mitigation disclosure risks. Besides that, we also assist our clients in
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obtaining U.S. tax identification number (ITIN)
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filing amendments to tax returns
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retrieving previously filed tax returns
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obtaining tax transcripts
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detailed audit and anti-fraud inspection of tax returns
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obtaining the certification of U.S. tax residency (form 6166).
To prepare your tax return correctly, we will need the following documentations. All personal information, provided to us is protected by the non-disclosure agreement and the laws of the State of New York.
STRUCTURING
Corporate structuring, structuring of assets and transactions
In the United States and in some other jurisdictions the same economic performance may entail entirely different tax consequences, depending on the type and structure of the legal entity, the type of legal title of the asset, the type of the contract and many other factors.
Our company provides thorough assistance in choosing the most suitable form of legal entity for your business. In practice, we carry out the detailed calculations of tax implications of our client's income pertaining to each form of entity. For instance, if you are considering to start your business, but not sure whether to establish it in form of an LLC or a corporation, we will model tax liability of each type of those entities that you could compare the numbers and make a chose.
In case of the group of legal entities, we provide assistance in establishing the holding structure with the lowest tax burden. We also advice on cross-border corporate structuring and utilizing such offshore and low tax jurisdictions as BVI, Belize, Seychelles, Panama.
The separate practice of our firm is dedicated to the issues of assets structuring. We assist our clients with minimization of tax burden through allocating the assets between the legal entities of a holding group as well as professional shifting the title to the person or entity in the lower tax bracket. We also manage the basis of the assets through amortization and depreciation instruments, and like-kind exchanges.
To learn more about our instruments and techniques, please request the fully confidential consultation.
Disputing Tax Bills
Estimating tax liability may be difficult not only for ordinary people, but even for the IRS. Timelines and procedure are the two most important aspects of handling tax disputes whether before IRS or courts. In the last years the percent of cases won solely on the procedural grounds increased drastically. That means that in some cases you may win the dispute against the IRS even if you actually owe taxes.
Usually, the starting point of your tax dispute is a receiving a letter from the IRS, which states the IRS believes you have received undeclared income. The first notice may be followed by the Examination Report (so-called "30-days letter") then. Herewith you are given 30 days to respond the IRS statements in form of an administrative protest. If you have filed your protest timely, you will be informed that your case is transferred to the IRS Appeals Division. The IRS Appeals Division may resolve your case at the location closest to you, but in some cases your case may be transferred to the far conner of the country.
Failing the to meet 30-days deadline for protesting may result in the Notice of Deficiency or so-called "90-days letter". There is only one permissible form of answer to the Notice of Deficiency - filing a petition to the U.S. Tax Court in Washington, D.C. Despite the fact that the U.S. Tax Court is located in Washington, D.C., petitioners are given the right to choose the city where your case to be heard by the traveling tax judge. The U.S. Tax Court sets forth simplified procedure rules. No jury trial is allowed.
Your right to dispute the the Notice of Deficiency shall be waived if you miss aforementioned deadline. However, you may contest your case in the U.S. District Court or the U.S. Claims Court. To file a petition to the U.S. District Court or the U.S. Claims Court you must first pay your taxes, which is not necessary for disputing your case in the U.S. Tax Court. Also, in some cases you may pay only the portion of the tax due to contest your case to the U.S. District Court or the U.S. Claims Court.
Whether you have paid your tax bill or not, we will assist you in disputing it before the IRS or in court. We are in partnership with several tax law attorneys and experts in seventh countries (USA, UK, Sweden, Russia, China, BVI, Panama).
Viacheslav Kutuzov | International & U.S. Taxation Expert
Viacheslav S. Kutuzov