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RJS LAW - Tax and Estate Planning

RJS LAW: San Diego Tax Attorney | IRS | FTB | CPA | California

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SOUTHERN CALIFORNIA’S FINEST
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(619) 595-1655
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(949) 535-2000
El CAJON
(619) 777-7700
  • Home
  • About
    • Ronson J. Shamoun, ESQ., LL.M.
    • Chandara Diep, ESQ., LL.M.
    • Joseph Cole, ESQ., LL.M.
    • Devon J. Arabo, ESQ., LL.M.
    • Lauren Suarez, ESQ., LL.M.
    • Daniel Huynh, Esq., LL.M.
    • Christopher Engelmann, ESQ., LL.M.
    • Brian M. Malloy, Esq.
    • Steve S. Mattia, Esq.
    • Sam Imandoust, ESQ., LL.M
    • Kaveh Imandoust, JD, MBT, CPA
    • Andrea Cisneros Valdez, Esq., LL.M.
    • Martin Schainbaum, ESQ., LL.M.
    • Dod Ghassemkhani, ESQ.
    • Vincent Renda, Esq.
    • Pedro Bernal, Esq.
    • Melanie M. Shamoun
    • Sandie Portilla
    • Renae Arabo
    • Sabri P. Shamoun
    • Hilary Dargavell
    • Lupita C. Torres
    • Jewell Cornejo
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          • How the IRS calculates interest
          • How to get a tax levy released
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          • IRS Collections Process
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          • IRS Revenue Officers
          • Jeopardy Assessments and Jeopardy Levies
          • National Tax Agencies
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          • IRS Statute of Limitations on Collections
          • Streamlined Installment Agreements
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          • Taxpayer Assistance Orders
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          • OVERVIEW OF OFFER IN COMPROMISE PROCESS
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          • Offer in Compromise and Dissipated Assets
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          • Why Choose RJS LAW?
          • Offer in Compromise Alternatives
          • Actual IRS Offer in Compromise Results
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        • California State Tax Matters – California Franchise Tax Board | FTB | EDD
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          • Discharging State Income Taxes in Bankruptcy
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        • Criminal Tax Defense – Tax Crimes
        • Currency Transaction Records & Suspicious Activity Reports
        • IRS Methods of Proof: Tax Fraud and Evasion
        • Methods IRS Agents Use to Locate Assets
        • IRS Special Agent Visits
        • Are You a Criminal Investigation Target?
        • Criminal Tax Attorney vs. White Collar Defense
      • CORPORATE TAXES
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      • Innocent Spouse Relief
    • International Tax
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    • Accidents & Injury
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      • Landlord Tenant Law
    • Employment Law
  • Tax Institute
    • 8th Annual USD School of Law – RJS LAW Tax Controversy Institute – July 28th, 2023
    • 7th Annual USD School of Law – RJS LAW Tax Controversy Institute – July 15th 2022
    • 6th Annual USD School of Law – RJS LAW Tax Controversy Institute
    • 5th Annual USD School of Law – RJS LAW Tax Controversy Institute
    • 4th Annual USD School of Law – RJS LAW Tax Controversy Institute
  • Testimonials
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WINNER OF THE UNION TRIBUNE SAN DIEGO'S BEST TAX LAW FIRM

 


8 YEARS

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Contact
Blog
  • Home
  • About
    • Ronson J. Shamoun, ESQ., LL.M.
    • Chandara Diep, ESQ., LL.M.
    • Joseph Cole, ESQ., LL.M.
    • Devon J. Arabo, ESQ., LL.M.
    • Lauren Suarez, ESQ., LL.M.
    • Daniel Huynh, Esq., LL.M.
    • Christopher Engelmann, ESQ., LL.M.
    • Brian M. Malloy, Esq.
    • Steve S. Mattia, Esq.
    • Sam Imandoust, ESQ., LL.M
    • Kaveh Imandoust, JD, MBT, CPA
    • Andrea Cisneros Valdez, Esq., LL.M.
    • Martin Schainbaum, ESQ., LL.M.
    • Dod Ghassemkhani, ESQ.
    • Vincent Renda, Esq.
    • Pedro Bernal, Esq.
    • Melanie M. Shamoun
    • Sandie Portilla
    • Renae Arabo
    • Sabri P. Shamoun
    • Hilary Dargavell
    • Lupita C. Torres
    • Jewell Cornejo
    • Kesia Belford
    • Remy Hogan
    • Judith Jeremie
    • Melanie Chan
    • Tanner DeMera
    • Asia Smith
  • Practices
    • ERTC – Call Us Before It’s Too Late!
    • Tax
      • IRS TAX MATTERS
        • IRS Appeals
          • IRS Appeals Process
          • Contesting an IRS Levy
          • Why Retain RJS LAW for IRS Appeals
          • 4 Tips For Navigating The IRS Rapid Appeals Process
        • IRS AUDITS
          • IRS Correspondence Audits
          • What are IRS Field Audits?
          • Initial IRS Compliance Center Audits
          • IRS Office Audits
          • What happens in an IRS Audit?
          • Taxpayer Rights Under IRS Publication 1
          • IRS Warns Taxpayers About Scam
        • NOTICES
          • IRS Notices
          • IRS Letters
          • FTB Notices
          • Avisos en Español
        • IRS Collections
          • Avoiding and Eliminating IRS Tax Liens
          • Collection Due Process Hearing
          • CP 501 – IRS Notice
          • Failure to file a tax return: What happens?
          • How the IRS calculates interest
          • How to get a tax levy released
          • ACS – Automated Collection System
          • IRS Collections Process
          • IRS Interest Abatement
          • IRS Revenue Officers
          • Jeopardy Assessments and Jeopardy Levies
          • National Tax Agencies
          • RJS LAW Approach to Collections
          • IRS Statute of Limitations on Collections
          • Streamlined Installment Agreements
          • Tax Penalty Abatement
          • Taxpayer Assistance Orders
        • IRS Payroll Tax
          • Independent Contractor Reclassification Audits
          • IRS Forms 940 and 941
          • IRS Trust Fund Interviews
          • Payroll Tax Liability Payment Options
          • Trust Fund Recovery Penalties
        • IRS Wealth Squad
        • Offer in Compromise & Tax Settlements
          • OVERVIEW OF OFFER IN COMPROMISE PROCESS
          • The Offer in Compromise Process
          • Appealing an Offer in Compromise
          • How does the IRS evaluate an Offer in Compromise
          • Offer in Compromise and Dissipated Assets
          • Offer in Compromise Requirements
          • Pros and Cons of an Offer in Compromise
          • Why Choose RJS LAW?
          • Offer in Compromise Alternatives
          • Actual IRS Offer in Compromise Results
      • STATE TAX MATTERS
        • EDD California Payroll Tax Lawyer
          • EDD Investigations
          • EDD Collections – Liens, Levies, and Garnishments
        • CDTFA – California Sales Tax
          • California Sales Tax Appeals
          • California Sales Tax Audits
          • California Department Of Tax And Fee Administration – CDTFA
        • California State Tax Matters – California Franchise Tax Board | FTB | EDD
          • California Residency Audits
          • Discharging State Income Taxes in Bankruptcy
          • State Tax Practice – Outside of California
      • CRIMINAL TAX ISSUES
        • Criminal Investigation Division
        • IRS Criminal Investigation Division Tactics
        • Criminal Tax Defense – Tax Crimes
        • Currency Transaction Records & Suspicious Activity Reports
        • IRS Methods of Proof: Tax Fraud and Evasion
        • Methods IRS Agents Use to Locate Assets
        • IRS Special Agent Visits
        • Are You a Criminal Investigation Target?
        • Criminal Tax Attorney vs. White Collar Defense
      • CORPORATE TAXES
      • TAX COURT LITIGATION
      • Innocent Spouse Relief
    • International Tax
    • Estate Planning
    • Trust Litigation
    • Trust, Estate & Probate Litigation
    • Trust & Estate Administration
    • Probate
    • Bankruptcy
    • Civil Litigation
    • Criminal Defense
    • Accidents & Injury
    • Corporate & Transactional
    • Private Wealth Services
    • Real Estate Law
      • Landlord Tenant Law
    • Employment Law
  • Tax Institute
    • 8th Annual USD School of Law – RJS LAW Tax Controversy Institute – July 28th, 2023
    • 7th Annual USD School of Law – RJS LAW Tax Controversy Institute – July 15th 2022
    • 6th Annual USD School of Law – RJS LAW Tax Controversy Institute
    • 5th Annual USD School of Law – RJS LAW Tax Controversy Institute
    • 4th Annual USD School of Law – RJS LAW Tax Controversy Institute
  • Testimonials
  • Giving
    • Giving
    • RJS LAW Donates Billboard to the Girl Scouts
  • Awards
    • Awards
    • Ronson J. Shamoun at events with various dignitaries
    • SD50 Extraordinary Leadership
    • Media
    • Video Gallery
  • Blog
  • Pay
  • Contact

International Tax

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Rethinking IRS Penalty Assessments: A Deep Dive into the Farhy v. Commissioner Ruling

Farhy v. Commissioner ruling

Farhy v. Commissioner In a recent landmark ruling, Farhy v. Commissioner, the Tax Court has significantly changed penalty assessments under I.R.C. Section 6038(b) of the Internal Revenue Code. This ruling, rendered on April 3, 2023, carries significant implications for a broad range of taxpayers, potentially offering a basis to challenge or request refunds for penalties

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Filed Under: International Tax, International Tax Attorney, International Tax Reporting Requirements, IRS Penalties Tagged With: Farhy v. Commissioner, international tax, irs penalty

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What You Need to Know About FinCEN Form 105 – Importing Currency into the United States

What You Need to Know About FinCEN Form 105 As a city with a direct border to Mexico, San Diego is a popular destination for our Mexican neighbors who need to know about the FinCen Form 105 in order to bring currency into the United States for business or personal use. Those planning to import

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Filed Under: FinCEN, Form 105, International Tax Tagged With: FinCEN, Form 105, international tax

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Leveraging the Benefits of Form 8833 for International Tax Treatment

Form 8833

The International Tax Law Team at RJS LAW receives numerous inquiries regarding a crucial yet often misunderstood element of United States tax law — IRS Form 8833, or the Treaty-Based Return Position Disclosure. For taxpayers engaged in global transactions, Form 8833 is significant as cross border transactions are often regulated by international tax treaties. What

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Filed Under: International Tax, International Tax Attorney, IRS Form 8833 Tagged With: Form 8833, international tax, International taxes

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Supreme Court Resolves FBAR Penalty Dispute: Per-Report Basis Confirmed

Introduction to the FBAR Penalty Dispute: In a significant decision, the U.S. Supreme Court recently ruled the penalty for violating the “Report of Foreign Bank and Financial Accounts” (FBAR) rules applies on a per-report basis, rather than a per-account basis. This decision brings clarity to a previously divided area of law, as the Fifth Circuit

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Filed Under: FBAR, FBAR Penalties, International Tax, International Tax Reporting Requirements, U.S. Supreme Court Tagged With: fbar, FBAR Penalties, FBAR Reporting, international tax, international tax attorney san diego, International Tax Lawyers San Diego, U.S. Supreme Court

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FBAR – Foreign Bank Accounts Require Disclosure

FBAR

FBAR – Foreign Bank Accounts Require Disclosure If you are U.S. Citizen or a Green Card holder and you have a bank account outside the United States, your foreign bank account(s) requires disclosure to the Internal Revenue Service (IRS) and the Financial Crimes Enforcement Network (FinCEN) through Form FinCEN 114 or FBAR. Every U.S. Citizen

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Filed Under: FBAR, Foreign Bank Accounts, International Tax, International Tax Attorney, International Tax Reporting Requirements Tagged With: fbar, Foreign Bank Accounts, international tax, international tax attorney

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Tax Treaty Provisions Are an Important Part of International Tax Reporting File IRS Form 8833 to Avoid Penalties!

Tax Treaty - IRS Form 8833

What is a Tax Treaty? A tax treaty is an agreement between two countries intended to address and resolve issues such as double taxation of income for each country’s citizens or residents. The United States has tax treaties in place with numerous countries. These treaties seek to provide reciprocal reduced tax rates or exemptions for

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Filed Under: International Tax, International Tax Attorney, International Tax Reporting Requirements, IRS Form 8833 Tagged With: international tax, international tax attorney san diego, International Tax Reporting, International Tax Reporting Requirements

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Breaking Down the Attorney Client Privilege Break Down

Attorney Client Privilege

Attorney Client Privilege The concept of attorney client privilege as we know it could be shifting in the Ninth Circuit. The 1981 case Upjohn Co. v. United States determined the purpose of attorney client privilege is to “encourage full and frank communication between attorneys and their clients.”1 However, when it comes to legal tax professionals

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Filed Under: International Tax, International Tax Attorney Tagged With: international tax, international tax attorney, international tax attorney san diego, Ninth Circuit Court of Appeals

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International Tax Law for Non-Profits

International Tax Law for Non-Profits

International Tax Law In today’s economic climate non-profit organizations are looking globally to support continuing operations.  However, in doing so, non-profits need to understand applicable international tax law and ensure compliance with applicable federal tax laws and IRS guidelines. This is especially important in cities like San Diego where non-profits may have operations in both

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Filed Under: International Tax, International Tax Law for Non-Profits, International Tax Reporting Requirements Tagged With: international tax attorney san diego, International Tax Law, International Tax Law for Non-Profits

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Internal Revenue Service Form 8938

Form 8938

An Important International Tax Form to Declare Foreign Financial Assets May be filed through the IRS Streamlined Procedures What is it Internal Revenue Form 8938? Form 8938 is used to report specified foreign financial assets when the overall value of the those specified foreign financial assets is over the appropriate reporting thresholds. The form requires

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Filed Under: International Tax, International Tax Attorney, International Tax Reporting Requirements Tagged With: international tax, international tax attorney, International Tax Reporting

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Complying with International Tax Reporting Requirements – Streamlined Procedures May Help

Streamlined Procedures

Streamlined Procedures – What Is It and Who Does It Assist? Streamlined Procedures may provide non-tax-compliant US citizens a remedy when the conduct was non-willful. The Streamline includes procedures and terms for filing amended or delinquent returns and for resolving open tax and penalty obligations. Part of the process includes filing three years of income

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Filed Under: International Tax, International Tax Attorney, International Tax Reporting Requirements, Streamlined Procedures Tagged With: international tax, international tax attorney, international tax attorney san diego, International Tax Reporting Requirements, Streamlined Procedures

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