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Old 09.02.2013, 18:38
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US tax attorney in/near Fribourg?

Anyone know of a US tax attorney in or near to Fribourg area? I know of one in Geneva and have read here on the forum of others that are based in Zurich/Winterthur areas, but would prefer one a bit nearer to home if I can find one. I've got to sort out the back tax situation once I've done my renunciation in March. So if there are any around Fribourg, Bulle, Neuchatel, Bern, etc, details would be welcome. Thanks.
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Old 09.02.2013, 18:52
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Re: US tax attorney in/near Fribourg?

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Anyone know of a US tax attorney in or near to Fribourg area? I know of one in Geneva and have read here on the forum of others that are based in Zurich/Winterthur areas, but would prefer one a bit nearer to home if I can find one. I've got to sort out the back tax situation once I've done my renunciation in March. So if there are any around Fribourg, Bulle, Neuchatel, Bern, etc, details would be welcome. Thanks.
Well the US Embassy has a list:
http://bern.usembassy.gov/am_attorneys.html

And ACA also has a list:
http://americansabroad.org/about/tax-advisory-panel/

I don't think Fribourg or Bern would have much since these are not really international business centers like Zurich and Geneva.
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Old 09.02.2013, 19:02
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Re: US tax attorney in/near Fribourg?

My wife used ACA (or was recommended one from there) and everything happened over the phone and email. She paid 500 chf for 3 years of taxes and he got her even more money back . hassle free and quickly handled as well.
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Old 09.02.2013, 19:09
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Re: US tax attorney in/near Fribourg?

Thanks, brusch and Anthony1406. I've been in contact with John Iglehart on the US Embassy list about something else last year so do know him. Was just hoping that there might be enough Americans in Bern for example that a few tax attorneys might have set up shop there. Not having filed before I've no idea how much paperwork they'd need on my side, but I'm guessing bank statements for last few years at least.
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Old 09.02.2013, 21:25
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Re: US tax attorney in/near Fribourg?

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Thanks, brusch and Anthony1406. I've been in contact with John Iglehart on the US Embassy list about something else last year so do know him. Was just hoping that there might be enough Americans in Bern for example that a few tax attorneys might have set up shop there. Not having filed before I've no idea how much paperwork they'd need on my side, but I'm guessing bank statements for last few years at least.
Don`t really need bank statements per see. I would think your Swiss tax returns would be a good place to start. Assuming you are a wage earner the Swiss income statement you get from your employer will be the main thing, pension statements for any pillar 2 employer contributions, any interest on bank accounts, and details if you have any share transactions.

Are you sure you need a tax lawyer and not a US tax accountant?

Are you in contact with the IRS? How far back do you have to go?
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Old 10.02.2013, 07:57
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Re: US tax attorney in/near Fribourg?

I'm not, the OH (British) is the wage earner, but we have joint accounts, no shares or investments otherwise. No IRS contact and have never filed, didn't know I needed to until the subject came up when sorting out our Swiss mortgage last year.
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Old 10.02.2013, 11:25
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Re: US tax attorney in/near Fribourg?

So I had a friend who was born in the USA, left when she was under 2 for Canada and never returned.

Lived here for a while and only on a business trip to the US got grief. She renounced and never completed a tax return.

If you`ve never been contacted by the IRS and they are willing to do your renouncement without getting the tax returns up to date I would ignore for now.

If you haven't earned a wage it should be a very simple exercise to complete the tax returns. You will stick your income on it which by the sounds of it is just your part of the interest, assuming you will qualify for the Foreign Earned Income Exclusion every return should be a nil return.

I would only think you would need a lawyer/ attorney if they get very arsey and hit you with some fines for non compliance and try and defined yourself. Otherwise I think you can do it yourself (or avoid altogether) if it`s just filing and lodging 0 returns.
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Old 10.02.2013, 14:53
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Re: US tax attorney in/near Fribourg?

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So I had a friend who was born in the USA, left when she was under 2 for Canada and never returned.

Lived here for a while and only on a business trip to the US got grief. She renounced and never completed a tax return.

If you`ve never been contacted by the IRS and they are willing to do your renouncement without getting the tax returns up to date I would ignore for now.

If you haven't earned a wage it should be a very simple exercise to complete the tax returns. You will stick your income on it which by the sounds of it is just your part of the interest, assuming you will qualify for the Foreign Earned Income Exclusion every return should be a nil return.

I would only think you would need a lawyer/ attorney if they get very arsey and hit you with some fines for non compliance and try and defined yourself. Otherwise I think you can do it yourself (or avoid altogether) if it`s just filing and lodging 0 returns.
should read "defend yourself"
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Old 10.02.2013, 16:10
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Re: US tax attorney in/near Fribourg?

How long ago did your friend renounce? If this was all happening a few years earlier I wouldn't be so concerned, but as details of any CLN's are passed on to the IRS and you have to tick whether you're tax compliant or not on the renunciation forms, I feel they're more than likely these days to do a follow up and check your tax situation. Otherwise, ignoring it would be a very good idea as I haven't lived there since 1969 and only ever had one summer job while still at school. I'd much prefer not to fill in the forms in the first place, but worry about our bank subsequently being contacted and our accounts being closed because I'm not tax compliant. I can't decide if the risk is worth it, or if it's better to do the filing to keep the Swiss bank happy.
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Old 10.02.2013, 16:54
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Re: US tax attorney in/near Fribourg?

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How long ago did your friend renounce? If this was all happening a few years earlier I wouldn't be so concerned, but as details of any CLN's are passed on to the IRS and you have to tick whether you're tax compliant or not on the renunciation forms, I feel they're more than likely these days to do a follow up and check your tax situation. Otherwise, ignoring it would be a very good idea as I haven't lived there since 1969 and only ever had one summer job while still at school. I'd much prefer not to fill in the forms in the first place, but worry about our bank subsequently being contacted and our accounts being closed because I'm not tax compliant. I can't decide if the risk is worth it, or if it's better to do the filing to keep the Swiss bank happy.
18 months ago. I would wait for them to ask. There are 2 different things here, tax returns and FATCA/ FBAR reporting, they will only go to your bank for the later. They asked our friend about tax returns and she just laughed at them. Have you ever given them bank details or is it on any of your forms?

If you are that worried I would talk to the embassy. My biggest worry would be them not allowing you to renounce because you haven't filed tax returns. If you get past renouncement I would be less concerned.

Their first steps will be to contact you asking for the returns not your bank.
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Old 10.02.2013, 17:21
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Re: US tax attorney in/near Fribourg?

No, the IRS don't know anything about the banking side. I never even got around to changing my SSN details from my single to married name because I never used it.

They can't actually stop you renouncing because even if you do, you are still liable for any tax owed after renunciation. Of course, if you've ticked that you're not compliant then I expect the tax situation will be mentioned, but it shouldn't have any effect on the actual renunciation. I have heard of some embassies in other parts of the world who are insisting that people are tax compliant before they renounce, but under the law it's none of the embassy's business whether you are or not. From the few reports I've read over on the Isaac Brock Society website, Bern are pretty good about the whole procedure. Only one appointment needed and CLN's are received about two months after the renunciation. Vancouver is totally the opposite, needs two appointments, usually over a year apart and another year or so before the CLN gets delivered. Ricidulous. People are actually preferring to travel hundreds of miles to another Canadian embassy rather than use Vancouver if at all possible.
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Old 05.03.2013, 14:30
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Re: US tax attorney in/near Fribourg?

Well, the renunciation was done yesterday, so just the tax side to sort out now.

From first being seen by a consular official until the actual oathtaking took no more than half an hour. Unfortunately, all told I was in the embassy from just before 10am until nearly 1130am due to the various waiting times inbetween things happening. Still, there were no problems apart from the waiting.
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Old 05.03.2013, 14:40
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Re: US tax attorney in/near Fribourg?

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Well, the renunciation was done yesterday, so just the tax side to sort out now.

From first being seen by a consular official until the actual oathtaking took no more than half an hour. Unfortunately, all told I was in the embassy from just before 10am until nearly 1130am due to the various waiting times inbetween things happening. Still, there were no problems apart from the waiting.

Thanks for sharing. I'm curious. Could you describe what happened during the visit? Did they ask you lots of questions? Did they try to get you to change your mind? Did they give any explanation about the US gov't doing anything to alleviate the difficult situation? etc ...??
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Old 05.03.2013, 14:46
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Re: US tax attorney in/near Fribourg?

Were you still looking for an attorney?

I do not know any in Fribourg, but one in Geneva, maybe the same one you know/found.
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Old 05.03.2013, 15:14
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Re: US tax attorney in/near Fribourg?

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Thanks for sharing. I'm curious. Could you describe what happened during the visit? Did they ask you lots of questions? Did they try to get you to change your mind? Did they give any explanation about the US gov't doing anything to alleviate the difficult situation? etc ...??
No, very few questions. Just checking that the info I had sent them on the questionnaire had been put on the Oath and Statement of Understanding properly. They had found my Social Security Number (worst luck) from a previous passport application I'd made. I'd put on the form that I couldn't remember if I'd ever had one so had put down that I didn't think I had one. But that was all and she kindly made a note of it so I had it for sorting out the tax side. Once I was happy that the forms were correct the lady directed me round to the payment window so I could do that part of it and then it was back to the waiting area until the Vice Consul appeared. No questions from him apart from to ask if I had read and understood both documents and then he read the oath and I said "I do" after. We both signed the forms and that was it. He said it would be 2-3 months for the CLN to arrive. That was all.

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Were you still looking for an attorney?

I do not know any in Fribourg, but one in Geneva, maybe the same one you know/found.
Yes, I am. I know of John Iglehart of Mudry & Iglehart who's based in Geneva, but I'm also going to take Anthony1406's advice and see what American Citizens Abroad can tell me. Brusch has provided a couple of links too which I'm hoping will be useful. Who do you know JBZ86?
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Old 05.03.2013, 15:23
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Re: US tax attorney in/near Fribourg?

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Yes, I am. I know of John Iglehart of Mudry & Iglehart who's based in Geneva, but I'm also going to take Anthony1406's advice and see what American Citizens Abroad can tell me. Brusch has provided a couple of links too which I'm hoping will be useful. Who do you know JBZ86?
Sent you a pm for now
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Old 06.03.2013, 20:00
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Re: US tax attorney in/near Fribourg?

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Thanks for sharing. I'm curious. Could you describe what happened during the visit? Did they ask you lots of questions? Did they try to get you to change your mind? Did they give any explanation about the US gov't doing anything to alleviate the difficult situation? etc ...??
I'm also curious--do you have to pay an exit tax? And, if so, what did you have to bring along to show what your worth would be? For example, do they ask for your recent Swiss tax returns?
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Old 06.03.2013, 20:05
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Re: US tax attorney in/near Fribourg?

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I'm also curious--do you have to pay an exit tax? And, if so, what did you have to bring along to show what your worth would be? For example, do they ask for your recent Swiss tax returns?
The determination of an exit tax is assessed based on the completion of the 8854.

The form will show your net worth, average liability for the last 5 years as well as other relevant info.

However, if you are a dual citizen by birth and have not lived in the US for 10 of the last 15 years you are exempt from exit tax.

Exit tax will be applied if any of the following apply and you are not a dual citizen by birth etc:

you have a net worth of US$ 2 million or more;
you have an average net U.S. income tax liability of greater than US$ 151,000 for the five year period prior to expatriation; or
you fail to certify that you have complied with all U.S. federal tax obligations for the preceding five years.
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Old 06.03.2013, 20:18
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Re: US tax attorney in/near Fribourg?

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I'm also curious--do you have to pay an exit tax? And, if so, what did you have to bring along to show what your worth would be? For example, do they ask for your recent Swiss tax returns?
The renunciation has nothing to do with the tax side of things T.Sue. They won't/shouldn't question you about your tax situation at all, apart from to point out to you that renouncing doesn't relieve you of your US tax obligations if they're not already up to date. This is also pointed out in the Statement of Understanding document that you sign as part of the renunciation process.

No, I will not have to pay an exit tax. I'm exempted because I was a dual national from birth, and also haven't resided in the US since 1968. So once I get the tax side sorted out by doing the necessary filings and paying any outstanding tax due that should be it.
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Old 06.03.2013, 22:25
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Re: US tax attorney in/near Fribourg?

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I'm exempted because I was a dual national from birth
Isn't there a clause stating that you also have to be taxed as a resident of your "other" country to benefit from the exemption? That was my understanding. Say if your other citizenship is british and live in Switzerland then you cannot use the exemption.
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