Denmark, France ,Sweden, Netherlands- IRS Notice/ Tax Bill/Tax Help

February 13, 2011
Written by: steve

Fresh Start Tax LLC        A Professional Tax Firm       “A” Rated by the BBB

IRS Tax Representation on all tax Matters and Issues.

IRS Specialists in taxpayers that IRS is making a collection attempt on citizens of other countries that the IRS has a tax treaty with.

We have been dealing with these issues since 1982 and have 25 year work history with the IRS.

Federal Tax Information

  1. In recent years, as our economy becomes more global, more and more U.S. taxpayers are participating in offshore activities for both legitimate and illegitimate purposes.
  2. Taxpayers who participate in offshore activities for illegitimate purposes seek to shelter financial resources in foreign countries. Offshore accounts can be located in any country in the world. Useful records can be obtained from foreign countries regarding theses taxpayers.
  3. International cases require methods not normally used in the domestic arena. Some of these methods are:
    • Exchange of Information (EOI)
    • Consent Directives
    • Letters of Request


Exchange of Information

  1. The United States has tax treaties and tax information exchange agreements (TIEAs) with many countries that provide for the exchange of information on tax matters.
    1. See IRM 5.1.8.7.7, Incoming Mutual Collection Assistance Requests regarding mutual collection assistance requests with the five treaty countries of Canada, Denmark, France, Netherlands and Sweden.
  2. The information requested may contain items that are reported or omitted on a taxpayer’s return or regarding the whereabouts of the taxpayer when the taxpayer no longer resides at the last known international address of record and in a delinquent return investigation to determine income and credits of the taxpayer.

    Access a list of countries that have an income tax treaty and/or a TIEA with the United States at: http://www.irs.gov/pub/irs-apa/treaty.pdf

  3. All Exchange of Information requests with a foreign country are handled by the IRS Tax Attaché, Revenue Service Representative (RSR) or Exchange of Information (EOI) group, as applicable, with the responsibility for handling request to the country where the information is located.
    1. See IRM 4.60.1 , Exchange of Information for more information on Exchange of Information between the United States and foreign countries.

    Tax Attachés and Deputy Tax Attachés serve in IRS overseas posts of duty and Revenue Service Representatives (RSRs) and Assistant Revenue Service Representatives (ARSRs) serve in IRS domestic posts of duty. Tax Attaches and RSRs service all functions of the IRS in tax administration matters within their respective post jurisdictions.

    The Exchange of Information Program administers the Exchange of Information provisions of U.S. tax treaties and tax information exchange agreements (TIEAs). EOI helps IRS field personnel obtain information from foreign countries, works with IRS field personnel to provide information to certain foreign countries, and coordinates the Mutual Collection Assistance provisions of certain treaties.

  4. All Exchange of Information requests with a U.S. Territory or State are handled by the Office of Governmental Liaison.

Types of Exchange of Information

  1. The types of information that may be exchanged under an Exchange of Information include but are not limited to:
    1. Tax returns and return information such as verification of filing status, citizenship, residency, income, expenses and tax liability,
    2. Third party information return filings,
    3. Bank records,
    4. Business records,
    5. Public records such as deeds, birth, death and marriage records, and
    6. Witness interviews.


Fresh Start Tax is one of the premier tax resolution firms in the country. We deal with all types of civil cases including individuals, businesses, non-profits, partnerships and corporations. We have staff that specialize in every facet of IRS representation. We know all the IRS tax strategies because of our extensive IRS working backgrounds. Some of our many specialties include the following:

  • Immediate Tax Representation
  • Offers in Compromise/Settlements
  • Immediate Release of Bank Garnishments or Wage Levies
  • IRS Notices/Bill of Intent to Levy or Final Notices
  • IRS Tax Audits, Large and Small Dollar
  • Hardships Cases, Payment Plans, Installment Agreements
  • Innocent Spouse Relief
  • Abatement of Penalties and Interest
  • State Sales Tax Cases
  • Trust Fund Penalty Cases/6672
  • Non-filers, never filed, old and past due tax returns

Our Company Resume: ( Since 1982 )


  • Our staff has over 135 years of professional tax representation experience collectively
  • On staff, Board Certified Tax Attorney’s, Certified Public Accountants, Enrolled Agents,
  • Former IRS Managers, Instructors and Trainers
  • Highest Rating by the Better Business Bureau “A”
  • Extremely ethical and moral
  • Fast, affordable, and economical
  • Licensed to practice in all 50 States
  • Premium on client communication
  • Nationally Recognized Veteran Former IRS Agent
  • Nationally Recognized Published Tax Expert
  • As heard on 90.3 FM Monthly Radio Show, You and the IRS


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