Tax Planning
Tax Research/Advisory
The U.S. Tax Code is particularly complex, more so with the Tax Cuts and Jobs Act of 2017. Sitting at nearly 2,600 pages long, the Tax Code has another 70,000 pages of interpreting the law, written by lawyers and accountants, to be read by lawyers and accountants. As such, the Tax Code can be difficult to navigate, even for professionals. Thus, when researching a tax rule, it is imperative to consult all resources, such as the Treasury Regulations and case law. The attorneys at Carbon Law Group are experienced in performing this type of intensive tax research for business development purposes or for individual taxpayers.
Business Tax Planning
Before making a business decision that could have negative tax consequences, it is important to seek comprehensive legal counsel from skilled taxation and corporate attorneys.
Transaction Tax
Advanced tax planning is key when negotiating a business transaction. We highly value the need for speed and efficiency that accompanies many of these transactions, and we work dynamically to resolve issues in a timely way to ensure that deals close on time without sacrificing exceptional results.
We work with transactions of all forms and handle all types of tax transactional issues for both domestic and foreign business entities.
- Business Tax Planning
- Business formation
- Tax Structure
- International Tax
- Foreign Entity Information
Business Tax Services
Entity Selection
Whether done through the acquisition of an existing business or through planning a new enterprise, a business’s potential for success is greatly influenced by the decisions made upon its formation. The question of “what is the right entity choice for me?” is best answered sooner than later. However, issues such as tax treatment can make the choice rather difficult. The choice will affect the tax characterization of business income, tax characterization of personal income received from business, the tax treatment of property exchanges you will make with your business, and your business’s potential management and ownership structures.
Selecting the right entity will require a careful analysis of both tax and nontax features of the various entities tailored to the unique characteristics of your business.
Tax Return Preparation
Corporation, Partnership, Limited Liability Company, etc. – all businesses require tax return preparation. We can professionally prepare your current tax returns or any overdue prior year tax returns along with estimated quarterly payments across both individual and business fronts.
International Tax Services
Foreign Bank Account Reporting (FBAR)
Taxpayers who hold overseas accounts or assets are required to disclose these assets through FBAR disclosure when the value of their account exceeds $10,000 at any time during the year. Failure to file FBAR can subject taxpayers to significant penalties, fines, and even a potential prison sentence. A willful FBAR violation, that is an intentional or voluntary disregard of the legal duty, can escalate the penalties rather quickly. Thus, it is imperative that taxpayers file their FBARs timely and diligently, more so than their federal or state tax returns. Your advisors at Carbon Law Group are ready to help you with all FBAR filings.
Passive Foreign Investment Company (PFIC) Advisory
- PFIC rules apply to Excess Distributions to US owners from their passive foreign investment companies. The rules impose an exceedingly high tax liability at ordinary income tax rates on such excess distributions.
- Determining whether a company is a PFIC is no easy feat and requires heavy analysis into the books of the entity to find out the passive vs non-passive asset and income ratios.
Here at Carbon Law Group, we can help you at all stages of PFIC advisory, from income and asset testing to filing the right forms to minimize your tax liability.
Inbound/Outbound Tax Planning
International tax planning is a complex area of law full of tax treaties and multi-jurisdictional tax rules. Carbon Law group will provide you with advice and guidance to accurately comply with these rules and take advantage of all potential advantages and planning opportunities.
Foreign Entity Information Tax Return Preparation (Forms 5471 and 8858)
Having interest in a foreign entity can potentially subject taxpayers to filing information tax returns for these entities. This will depend on whether the taxpayer falls into the categories specified by the Treasury, mandating the filing. Whether it is a disregarded entity, or a corporation, the attorneys at Carbon Law Group will make sure your foreign filings are made timely and accurately.