Streamlined Domestic Offshore Procedures (Brazil)

A U.S. citizen (“Client”) held bank accounts and residential rental property in Brazil in excess of $10,000. Client was not aware of their U.S. tax reporting requirements for foreign assets and never reported taxable foreign income on their U.S. tax returns. Client also failed to file FinCEN Form 114 Report of Foreign Bank and Financial Accounts (FBAR). DeWitt Law represented Client before the IRS to reach full filing compliance through…

Audit Reconsideration – Reversed Assessment

Client failed to respond to an IRS audit for tax year 2011 and $93,567 in additional tax ($168,516 with penalties and interest) was assessed. Because Client did not respond to the audit, file a timely appeal with the IRS, or file a Petition in U.S. Tax Court, the IRS took collection action against Client, including levy and garnishment. Client then hired DeWitt Law for representation. An audit reconsideration claim was…