I. What is Required of the Person Receiving the Gift?
II. Is the Gift or Bequest Taxable?
III. What are the Penalties for not Properly Reporting?
IV. Are there any Tax Planning Opportunities Available??
V. What are the Tax Compliance Obligations for the Person Making the Gift?
VI. Fitting All Wealth Management Puzzle Pieces Together
VII. About Freeman Tax Law
VIII. Relevant Resources
If you are a U.S. person who received foreign gifts or bequests of money or other property from a “non-U.S. person”, there are several reporting requirements that may apply. Tread carefully, however, because the failure to report foreign gifts properly could result in significant penalties.
If the value of aggregate foreign gifts that you receive during any tax year exceeds $100,000, you must report each foreign gift to the IRS. A foreign gift is any amount you receive from a non-U.S. person which you treat as a gift, bequest, or inheritance. A non-U.S. person is any person other than a citizen or resident of the U.S. or a U.S. partnership or corporation. The term non-U.S. person also includes a foreign estate. Foreign gifts don’t include qualified tuition or medical payments made on behalf of the recipient, or gifts which are otherwise properly disclosed on a return under the separate requirements applicable to amounts received from foreign trusts.
For purposes of determining whether the receipt of a gift from a foreign person is reportable, different reporting thresholds are applied for gifts received from nonresident alien individuals, foreign estates, gifts from foreign partnerships, and foreign corporations. So, a U.S. person is required to report the receipt of gifts from a nonresident alien or foreign estate only if the total amount of gifts from that nonresident alien or foreign estate is more than $100,000 during the tax year. Once the $100,000 threshold has been met, the one who receives the gift must separately declare each gift more than $5,000, but does not have to identify the donor.
A U.S. person must report the receipt of purported gifts from foreign corporations and foreign partnerships if the total amount of purported gifts from all such entities during the tax year is more than $10,000, subject to cost-of-living adjustments. Once the threshold has been met, the gift recipient must separately identify all purported gifts from a foreign corporation or foreign partnership, and provide the name of the donor.
If you fall within these reporting rules, you have to file Form 3520; Annual Return to Report Transactions With Foreign Trusts and Receipt of Certain Foreign Gifts. The form is due on the date that your income tax return is due, including extensions.
Penalties for Failure to File Form 3520
Under IRC Section 6677,a penalty generally applies if Form 3520 is not timely filed or if the information is incomplete or incorrect. Generally, the initial penalty is equal to the greater of $10,000 or:
- 35% of the gross value of any property transferred to a foreign trust for failure by a U.S. transferor to report the creation of or transfer to a foreign trust or
- 35% of the gross value of the distributions received from a foreign trust for failure by a U.S. person to report receipt of the distribution or
- 5% of the gross value of the portion of the trust’s assets treated as owned by a U.S. person for failure by the U.S. person to report the U.S. owner information.
Additional penalties will be imposed if the noncompliance continues after the IRS mails a notice of failure to comply with the required reporting.
Reasonable cause exceptions may apply.
No penalties will be imposed if the taxpayer can demonstrate that the failure to comply was due to reasonable cause and not willful neglect. For example, if the gift was disclosed to the preparer of your tax return, and incorrect advice was given regarding the requirements of this form, it may be possible to argue that you relied on a professional preparer to your detriment and therefore your reliance on this professional excuses your negligence in filing the form. Discuss all reasons and circumstances with a qualified tax attorney if you failed to file this form.
The fact that a foreign country would impose penalties for disclosing the required information is not reasonable cause. Similarly, reluctance on the part of a foreign fiduciary or provisions in the trust instrument that prevent the disclosure of required information is not reasonable cause.
Under IRC Section 6039F, other penalties may be applicable. In the case of a failure to report foreign gifts described in section 6039F, a penalty equal to 5% of the amount of such foreign gifts applies for each month for which the failure to report continues (not to exceed a total of 25%). No penalty will be imposed if the taxpayer can demonstrate that the failure to comply was due to reasonable cause and not willful neglect.
Under IRC Section 6662(j), penalties may be imposed for undisclosed foreign financial asset understatements. No penalty will be imposed; however, with respect to any portion of an underpayment if the taxpayer can demonstrate that the failure to comply was due to reasonable cause with respect to such portion of the underpayment and the taxpayer acted in good faith with respect to such portion of the underpayment.
Other Forms that may be Required
Receiving gifts can also trigger the need to file several additional forms and other tax obligations. You must alert your CPA regarding assets and income earned abroad and discuss their impact on your 1040 tax filing. Having foreign assets can trigger the filing of many forms including: Form 5471 for reporting your interest in certain foreign corporations, Form 8865 for reporting interests in certain foreign partnerships, Foreign Bank Account Report (FinCen Form 114), Form 8938, Form 1116, Form 8621 and several others. Failing to file these forms can result in significant penalties. It is crucial to explain all facts to your tax preparer and make sure that the preparer is qualified to handle filing returns with these issues.
In general terms, the donee is subject to tax on the receipt of a gift, only if the donor fails to file a Form 709 allocating exemption or pay the required tax, or the donor’s estate fails to file a Form 706 allocating exemption or paying the required tax. This, of course, assumes that the value of the gift exceeds the annual exclusion for purposes of estate and gift tax in the United States.
If the donor is a foreign person, and the gift received does not have a U.S. situs, there is no tax associated with the receipt of the gift. To the extent the donor is a “covered expatriate,” as the term is defined in Internal Revenue Code Section 877A(g), however, the donee is required to pay gift tax on the value of the gift, and the situs of the gift is irrelevant. The rules discussing “Covered Expatriates” are discussed below.
Special Rules for Gifts or Bequests from Covered Expatriates
A U.S. citizen who gives up U.S. citizenship or a long-term U.S. resident who gives up his residency status and who is a “covered expatriate” is subject to a mark-to-market rule. Under this rule, his property is deemed to be sold on the day before the expatriation, and he is taxed on the gain in excess of an inflation-adjusted amount of $693,000 for 2016 ($690,000 for 2015).
A covered expatriate is any U.S. citizen who relinquishes citizenship, or any long-term U.S. resident who ceases to be a lawful permanent resident of the U.S, who meets one of the following tests:
(1) the individual’s average annual net income tax for the period of 5 tax years ending before the date U.S. citizenship or residency is lost is greater than an inflation adjusted amount that is $161,000 for 2016 ($160,000 for 2015),
(2) the net worth of the individual as of the date U.S. citizenship or residency is lost is $2,000,000 or more, or
(3) the individual fails to certify under penalty of perjury that he has met the requirements of the U.S. tax code for the 5 preceding tax years or fails to submit whatever evidence of his compliance that IRS requires.
All the property of a covered expatriate is treated as sold on the day before the expatriation date for its fair market value. Any gain on the deemed sale is recognized, notwithstanding any other nonrecognition rules, and is taken into account for the tax year of the deemed sale, but losses may not be recognized if they would otherwise not be recognized. The basis of the assets will be adjusted by the amount of gain or loss taken into account.
A covered expatriate may make an election to defer the payment of tax attributable to any property that is deemed sold under the mark-to-market rule. A tax deferral under these rules bears interest from the due date of the taxpayer’s return for the expatriation year and is permitted only if the expatriate provides adequate security.
Deferred compensation items of a covered expatriate are subject to special rules. Eligible deferred compensation is subject to 30% withholding. The present value of deferred compensation that is not eligible deferred compensation is treated as received by the covered expatriate on the day before the expatriation date as a distribution. In addition, deferred compensation items that would otherwise not be taken into account under Code Sec. 83 will be treated as becoming transferable and not subject to a substantial risk of forfeiture on the day before the expatriation date.
The expatriation rules are complicated, and the above discussion is a short summary of those rules. If you have questions about your U.S. tax obligations as an expatriate or are considering giving up your U.S. citizenship or terminating your U.S. long-term residency status, before you make a move, please contact us to discuss your situation and some possible planning strategies.
U.S. citizens and residents who receive gifts or bequests from covered expatriates under IRC 877A may be subject to tax under new IRC section 2801. This imposes a transfer tax on U.S. persons who receive gifts or bequests on or after June 17, 2008, from such former U.S. citizens or former U.S. lawful permanent residents.
In addition, covered expatriates under IRC 877A are not considered U.S. expatriates for purposes of Form 706NA, United States Estate (and Generation-Skipping) Tax Return, of a nonresident not a citizen of the United States. So if you decide to gift after expatriation, Congress has established rules to prevent those taxpayers that are “creative”.
Where appropriate, planning opportunities exist which may allow you to avoid the reporting requirements. For example, if you are expecting a gift of $120,000 from a nonresident alien individual or foreign estate, it may be possible to arrange for the gift to be paid over two years, so that in neither year does the gift exceed $100,000. If the split gift is the only foreign gift you receive each year, you will avoid the reporting requirement. Alternatively, if we can arrange for part of the gift to be made in the form of qualified tuition or medical payments, the rest of the gift may be reduced enough to avoid the reporting requirement.
Gift and Estate Tax Planning for U.S. Domiciliary or Individual Immigrating to the U.S.A
High-net-worth individuals who spend extended time in the U.S., or are considering immigrating to the United States, may incur huge tax costs if they do not obtain advice to properly plan their estates prior to coming to the U.S.
How is U.S. Residency and Domicile Established?
A person is not subject to U.S. gift or estate tax unless they are a U.S. citizen or domiciliary (Regs. Sec. 20.0-1(b)(1)). Residency for federal income tax purposes is different from domiciliary status for federal gift and estate tax purposes, and this distinction can often result in a person’s having residency for income tax but not for estate or gift tax purposes (or vice versa).
What is Domiciliary Status in Regards to Gift and Estate Tax?
Unlike the generally clear and objective tests used to determine residency status for income tax purposes, the determination of a person’s domicile for estate and gift tax purposes is mostly subjective, and based on a facts-and-circumstances analysis.
Domiciliary status is acquired when one lives in the United States, even for a brief period, with no definite present intention of moving from the United States (Regs. Sec. 20.0-1(b)(1)). This means a person avoiding residency for U.S. income tax purposes does not necessarily remove the possibility of becoming a U.S. domiciliary for U.S. gift and estate tax purposes.
A person who is a U.S. domiciliary for estate and gift tax purpose is subject to gift tax at rates as high as 40% on that person’s worldwide gratuitous lifetime transfers of property. In addition, U.S. domicile status could result in the person’s worldwide assets’ being exposed to federal estate tax upon death at rates as high as 40%. However, a non-U.S. domiciliary’s estate and gift tax exposure extends only to gifts, bequests, and estate holdings of U.S. situs property (Sec. 2106). Certain U.S. situs property that is subject to the estate tax is not subject to the gift tax.
U.S. Situs Property - Property Subject to Estate Tax
1. Real Property
All real property located in the U.S., including condominium apartments, is subject to the estate tax.
2. Tangible Personal Property
Art, jewelry, gold coins, cash in a safe deposit box, furniture,and other tangible property located in the U.S. are subject to the estate tax. Works of art on loan or exhibition, however, may be exempt from the estate tax if special conditions are met.
3. U.S. Equities
Shares of stock in U.S. companies, whether publicly traded or privately held (including shares of stock in a co-operative apartment corporation), and regardless of the location of the share certificates,are subject to the estate tax. Shares in a U.S. registered investment fund (“RIC”), including mutual funds, are U.S. situs property subject to the estate tax.
4. Non Bank Deposits
Cash accounts with U.S. brokerage firms are not considered bank deposits and are subject to the estate tax.
Non U.S. Situs Property - Not Subject to the Estate Tax
1. Real Property Outside the U.S.
Real property located outside the U.S. is not subject to the estate tax.
2. Tangible Personal Property Outside the U.S.
Tangible personal property located outside the United States is not subject to the estate tax.
3. Stock in Foreign Corporations
Shares in foreign corporations,whether publicly traded or privately held,are not subject to the U.S. estate tax regardless of the location of the share certificates.
4. Insurance Proceeds
Amounts received as insurance on a decedent’s life are not subject to the estate tax.
5. Certain Debt Obligations
Bonds of U.S. companies,U.S. government, and U.S.government agencies are exempt from estate tax.
6. Bank Accounts
Generally, cash on deposit with a U.S.bank or insurance company (not with a brokerage firm) is not subject to the estate tax.
Non-Situs property is wehre a lot of tax planning occurs. Specifically, in situtations where a high-net-worth foreign-baed family member decides to move to the U.S., there is alot that can be done to avoid future tax.
Foreigners are subject to gift tax only on gifts of U.S. situs real estate and tangible personal property located in the United States. There is no gift tax on a gift of cash if the gift is by check or by wire transfer. Also, there is no gift tax on the gift of securities of a U.S. company, even though such assets may be subject to estate tax.
Tips to Help Minimize Gift and Estate Taxes
Below are a couple of situations in which taxes can be significantly minimized.
Gifts to U.S. persons: Assuming a desire to so do, it is advisable to make gifts to U.S. persons before becoming a U.S. domiciliary because nonresidents are subject to U.S. gift tax only on gratuitous lifetime transfers of U.S. situs property (including U.S. real estate and tangible property located in the United States, such as cars, art, jewelry, and furnishings) (Sec. 2101(a)).
Gifts between spouses: If a spouse becomes a U.S. resident but not U.S. citizens, any gifts between them in excess of $148,000 per year (2016 amount) will be subject to gift tax. Thus, any gifts between spouses should be made before entering the United States with non-U.S. situs assets (Sec. 2523(i)).
If the donor of a gift is a U.S. citizen or permanent resident, the donor is entitled to the unified credit in Sections 2010 and 2505, which can be used to offset the estate tax in Section 2001 on the value of the gift or the gift tax in Section 2501 on the value of the gift. The extent to which the unified credit is unavailable or the value of the gift exceeds the credit, the donor is required to pay the resulting estate or gift tax.
The donor must file a Form 709, if the gift is made during the life of the donor. If a bequest is made, the donor’s estate must file a Form 706, when the gift comes from a donor’s estate. In general, the IRS must assess any gift tax within three years after Form 709 is filed or estate tax within three years of the Form 706 being filed. A failure to file Form 706 or 709 prevents the statute of limitation from starting.
It is also important to recognize if a gift tax return is filed, but a gift is either omitted from the return or not adequately described, the statute does not commence, and the IRS can assess the gift tax at any time. Thus, a gift that is disclosed on the Form 709 or in a statement attached to the return should be identified in a matter that is “adequate to apprise the [IRS] of the nature” of the gift, so that the statute will begin to run. Unlike with gift tax returns, there is no method by which the examination of an estate tax return can be extended.
This is what should be disclosed:
(1.) A description of the transferred property and any consideration the transferor received.
(2.) The identity of, and relationship between, the transferor and each transferee.
(3.) If the property is transferred in trust, the trust’s tax identification number and a brief description of the terms of the trust. In lieu of a brief description of the trust terms, a copy of the trust instrument may be provided.
(4.) A detailed description of the method used to determine the fair market value of property transferred. This includes any financial data (e.g., balance sheets with explanations of any adjustments) used in determining the value of the interest; any restrictions on the transferred property that were considered in determining the fair market value of the property; and a description of any discounts, such as discounts for blockage, minority or fractional interests, and lack of marketability, claimed in valuing the property. With respect to the transfer of an interest in an entity (e.g., a corporation or partnership) that is not actively traded, a description must be provided of any discount claimed in valuing the interests in the entity or any assets owned by that entity. In addition, if the value of the entity or of the interests in the entity is properly determined based on the net value of the assets held by the entity, a statement must be provided regarding the fair market value of 100% of the entity (determined without regard to any discounts in valuing the entity or any assets owned by the entity), the pro rata portion of the entity subject to the transfer, and the fair market value of the transferred interest as reported on the return. If 100% of the value of the entity is not disclosed, the taxpayer bears the burden of demonstrating that the fair market value of the entity is properly determined by a method other than a method based on the net value of the assets held by the entity.
(5.) A statement describing any position taken that is contrary to any proposed, temporary, or final regulations or revenue rulings published at the time of the transfer.
Here are 8 ways from the IRS to determine if your gift is taxable:
If you gave money or property to someone as a gift, you may owe federal gift tax. Many gifts are not subject to the gift tax, but the IRS offers the following eight tips about gifts and the gift tax.
1. Most gifts are not subject to the gift tax. For example, there is usually no tax if you make a gift to your spouse or to a charity. If you make a gift to someone else, the gift tax usually does not apply until the value of the gifts you give that person exceeds the annual exclusion for the year. For 2016, the annual exclusion is $14,000.
2. Gift tax returns do not need to be filed unless you give someone, other than your spouse, money or property worth more than the annual exclusion for that year.
3. Generally, the person who receives your gift will not have to pay any federal gift tax because of it. Also, that person will not have to pay income tax on the value of the gift received.
4. Making a gift does not ordinarily affect your federal income tax. You cannot deduct the value of gifts you make (other than deductible charitable contributions).
5. The general rule is that any gift is a taxable gift. However, there are many exceptions to this rule. The following gifts are not taxable gifts:
• Gifts that are do not exceed the annual exclusion for the calendar year,
• Tuition or medical expenses you pay directly to a medical or educational institution for someone,
• Gifts to your spouse,
• Gifts to a political organization for its use, and
• Gifts to charities.
6. You and your spouse can make a gift up to $26,000 to a third party without making a taxable gift. The gift can be considered as made one-half by you and one-half by your spouse. If you split a gift you made, you must file a gift tax return to show that you and your spouse agree to use gift splitting. You must file a Form 709, United States Gift (and Generation-Skipping Transfer) Tax Return, even if half of the split gift is less than the annual exclusion
7. You must file a gift tax return on Form 709, if any of the following apply:
• You gave gifts to at least one person (other than your spouse) that are more than the annual exclusion for the year.
• You and your spouse are splitting a gift.
• You gave someone (other than your spouse) a gift of a future interest that he
or she cannot actually possess, enjoy, or receive income from until some time in the future.
• You gave your spouse an interest in property that will terminate due to a future event.
8. You do not have to file a gift tax return to report gifts to political organizations and gifts made by paying someone’s tuition or medical expenses.
As complex as foreign tax compliance can be, it is only one piece of the entire tax and wealth management puzzle. Tax planning and issue resolution, estate planning, and gift planning are just some of the other pieces that need to be addressed correctly to complete the puzzle.
To be properly invested and protected from tax compliance and foreign country pitfalls, it’s important to work with a team that can view your entire financial picture in a comprehensive and coordinated way. Seek out a team that can see both the big picture and the smallest of details at the same time. Look for:
1. Global and microscopic insights working hand in hand
In some ways, it’s similar to a surgical procedure. The patient needs both the big-picture perspective of a coordinated team and a detailed follow-through to ensure that everything is addressed. Handling big-picture and minute details together is critical to developing the most effective strategy, creating and maintaining a safety net, and instilling peace of mind.
2. Insightful interpretation of the issues, coupled with clear communication
Most people don’t have the stomach to learn codes and regulations filled with legal and tax gobbledygook. They want, and deserve, a team that can explain everything in clear terms and offer accompanying insights about how to proceed, based on its years of experience and expertise. (It’s not just the number of years; it’s what you do with those years.)
3. Technology that streamlines processes
This is especially critical when dealing with foreign governments and offshore entities. Incompatible systems, breakdowns, slow performance, “misplaced” files and inadequate security all create nightmares when working in a complicated wealth management arena that can span the globe. Verify that current systems that consistently provide accurate and reliable interactions and transactions involving foreign institutions, languages, and the like are in place and working properly. Pay special attention to security measures in place to protect sensitive information from hackers and unauthorized personnel.
4. World-class bedside manner
That surgeon in #1 above who needs to be so skilled and attentive to the operation itself also must practice kind and caring bedside manner. Let’s face it, too many professions, industries, and companies are filled with people who don’t connect with their stakeholders. There is no excuse in healthcare for arrogance and indifference when dealing with people’s lives. The same is true in the tax law and wealth management realms. People can get anxious, scared, angry, frustrated and overwhelmed with all the complexities and pitfalls. Work with a team that knows and shows how to care, will take the time to make sure that understanding is complete, and work to establish that comfort to the greatest extent.
5. Clear direction and guidance about pricing
No one, from the most modest to high-rolling investor, should have to endure the scourge of unclear pricing structure and payment terms. While there are typically variables that can’t be fully predicted at the outset, the team should be able and willing to explain how charges accrue, conveying appropriate estimates and ranges, and payment terms and timeframes in a straightforward and easily understood manner. When unexpected issues or complications arise, the team should be timely and complete in notifying the client about what’s going on, and options available.
The biggest challenge in building a tax and wealth management team is cohesion and a common playbook. Too many investors have a corporate attorney, CPA/tax advisor, financial planner, investment advisor, estate planning advisor and other advisors as separate entities. Besides lacking a common plan and understanding, this approach carries the omnipresent threat of “viewpoint tunnel vision.” An attorney will provide one perspective, a CPA another, and the financial planner may be on an entirely different page—and so forth. Then, it becomes incumbent on the client to weave all this disparate information together and try to make sense of it all.
In contrast, Freeman Tax Law puts the team in place for clients; it functions like a well-oiled machine. Internally and through strategic partnerships the firm offers tax law, accounting, estate planning, financial planning, and wealth management services. Depending on the client’s needs and already-established relationships, Freeman Tax Law can coordinate with the client’s advisors and wrap them into the team structure; rounding out representation with internal and strategic partnership resources. Bottom line, a well-coordinated team with agreed-upon objectives and clear direction will set out to cover all the bases—from managing money to meeting tax obligations.
In terms of core specialties, Freeman Tax Law is dedicated to its longstanding mission: Working predominately with individuals and businesses across the country on all domestic and international tax law matters. The firm has helped resolve a wide range of complex tax controversies dealing with delinquent filings, audits and criminal tax investigations, offshore banking taxation, estate challenges, wealth management, gift planning, bankruptcy and more.
Within the firm, Freeman Tax Law offers the services of attorneys, former IRS Agents, CPAs, consulting professionals, and professional staff that collectively have vast experience handling and resolving tax controversies. This team is well-versed in knowledge of IRS procedures, reconstructive accounting, white collar criminal defense, bankruptcy and estate planning. From this wealth of resources, the firm assembles a tailor-made team to address client needs.
Freeman uses a process that makes sure to cover all bases, and provides the client a clear picture of what we’re doing and where we’re going. Fundamentally, this process includes:
1. Information Gathering
This is where we collect pertinent documents to get an initial view of the situation and assess where the client stands presently. A state-of-the-art, secure portal enables efficient and safe sharing of information. From the compiled data, we develop initial ideas about scope and timing of needed services—from disentangling foreign investments and associated complicated tax compliance challenges and/or non-compliance consequences to recommending US investments that will meet desired client criteria and moving foreign deposits into the appropriate silos.
2. Succinct Work-Plan
Based on analysis and a good in-depth understanding of the client’s situation, Freeman develops a work-plan. The outline of an appropriate investment plan addresses such cornerstone issues as risk tolerance level and desired income—ensuring full tax reporting and compliance every step of the way. By employing this comprehensive approach, Freeman helps ensure that a successful wealth management program reaches its potential instead of being thwarted by the ominous long arms of the tax authorities.
In the tax law arena specifically, Freeman develops a straightforward strategy that covers every aspect of the client’s tax plan [e.g., to file necessary returns and other needed forms (e.g., 3520, 709. 706, 8865, FBAR)] and address associated issues. These issues can be very complicated, from having to deal with treaty issues to determining what income can be excluded from taxation. Everything is double-checked with the IRS to ensure full compliance and to avoid later unpleasant surprises.
3. Assembling the Puzzle
After the comprehensive work-plan has been assembled, it is vetted among the team to tighten, fill in any blanks, and reassess and revise as necessary. The resulting plan should feel strong, tight, and doable to all team members (e.g., the recommended investment strategies align with the client’s desired outcomes and ensure full and timely handling of all tax-related issues and requirements). The plan will be made available to the client and all team members in an easily accessed format for easy reference and review as desired.
4. Moving forward
The plan is implemented, with the appropriate team members overseeing their portion of the process. To ensure staying on track, regular reviews and evaluations will be conducted. Besides providing the obvious continuity, this can spot potential trouble spots or conflicts (e.g., a tax problem) before they blossom into real problems with substantial consequences.
About the author
Jeffrey S. Freeman, J.D., LL.M.
Jeffrey S. Freeman, Esq. has personally represented and counseled hundreds of clients throughout the United States on tax matters. Jeff’s objective is handle complex tax matters efficiently, creatively and strategically, and provide his clients complete, cost-effective representation and resolution.
Jeff represents clients with a variety of backgrounds and professions. He has successfully negotiated and resolved complex tax controversies for his clients before the IRS and in the Federal Court system, U.S. Tax Court, State Tax Courts, and the U.S. Bankruptcy Court. Further, Jeff has skillfully handled audits with various taxing authorities, the settlement of tax liabilities with the IRS, negotiation of installment agreements, Offer in Compromises, removal of tax liens and levies, sales tax and payroll trust fund tax assessments, innocent spouse relief claims and the removal of penalties and interest for his clients.
Jeff holds a Masters of Law in Taxation (LL.M.) from Georgetown University Law Center in Washington, D.C. and Juris Doctor, Cum Laude, from the Michigan State University College of Law and a Bachelor of Arts in Accounting, with honor, from Michigan State University where he was a member of the Beta Gamma Sigma Business Honor Society and the Phi Kappa Phi Academic Honor Society.
Further, he is a member of the Taxation Section of the American Bar Association and Michigan Bar Association, where he served as a past chair of the Tax Practice and Procedure Committee. In addition to the state courts in Michigan, Jeff is admitted to practice before the United States Federal Court, United States Court of Appeals and in the United States Tax Court.
With national recognition for his work and commentary, Jeff has appeared on the Frank Beckman Show, Fox News, and has been quoted in Newsweek, The Motley Fool, Business Week, the Detroit News, Detroit Free Press, Crain’s Business, and Detroit Business. Over the years, he has authored numerous articles for various professional journals.
He has been named a “Top Lawyer” by Detroit’s dbusiness magazine; and has been the keynote speaker about the Foreign Account Tax Compliance Act (FATCA) at the American Chamber of Commerce in Shanghai, China.
This eBook has been prepared by Freeman Tax Law for informational purposes only, and does not constitute legal or tax advice. The information is not intended to create, and receipt of it does not constitute, an attorney-client relationship. You should evaluate the information made available through this eBook, and then seek the advice of professionals, as appropriate, to evaluate any information or opinions contained herein.
In no event shall Freeman Tax Law or any of its partners, officers, employees, agents or affiliates be liable, directly or indirectly, under any theory of law (contract, tort, negligence or otherwise), to you or anyone else, for any claims, losses or damages, direct, indirect special, incidental, punitive or consequential, resulting from or occasioned by the creation, use of or reliance on this eBook.