Our team of US tax lawyers and CPAs can prepare and file complex individual returns, partnership returns, S corporation returns, corporate returns, trust returns, and gift/estate tax returns both at the Federal and state levels. While our focus is on clients with international connections - whether it be through dual citizenship, foreign investments by US persons, or US investments by foreigners – we also have extensive experience filing for US individual and businesses whose primary income stream is generated purely within the United States.
US tax filing obligations are notoriously complicated and far reaching. We strive to ensure that our clients remain in compliance with US tax authorities while utilizing any and all available legal strategies to mitigate the incidence and amount of taxation to which they may be subject.
Our services also include:
Tax Return Review –Review and sign returns prepared by your in-house tax team or other firms
Act as your in-house Tax Team – Assist in preparation of interim and annual tax workpapers used for estimated tax payments or tax provisions
COMPREHENSIVE AND INTEGRATED COMPLIANCE AND PLANNING
INTERNATIONAL TAX AND IRS DISCLOSURE SERVICES
Since the enactment of the Foreign Account Tax Compliance Act (‘FATCA’) in 2010, the IRS has engaged in significant administrative and regulatory actions to ensure that US citizens and residents report and pay tax on all of their foreign investments, accounts, and income. The lynchpin of these efforts is the mandatory reporting of certain foreign financial assets and accounts held by US persons to foreign tax authorities; this information is then automatically shared with the IRS in an effort to identify companies, trusts, and individuals who have failed to properly report such assets and accounts and pay the required tax.
Unfortunately, the complexity and breadth of FATCA has historically caused many US persons who have inadvertently failed to comply with foreign reporting requirements to incur a litany of civil penalties and in the most egregious of cases, criminal exposure.
We help clients who have not complied with these requirements and have already been identified by the IRS. We also frequently work with those clients who have become aware of their foreign reporting obligations and wish to become compliant through several voluntary disclosure initiatives offered by the IRS. Whether it be through an audit, appeal, judicial proceedings, or voluntary disclosure, our aim is to bring our clients into full compliance while simultaneously mitigating all potential tax, interest, and penalties which may apply.
Streamlined Domestic Offshore Procedures – Available to certain US persons residing within the United States with unreported foreign financial assets and/or income
Streamlined Foreign Offshore Procedures (SFOP) – Available to certain US persons residing abroad with unreported foreign financial assets and/or income
Delinquent IRS Submission Procedure – Available for certain US persons who do not need the full protection of the Streamlined Procedures but who have failed to properly file FBARs (Delinquent FBAR Submission Procedures) or international reporting forms (Delinquent International Information Return Submission Procedures)
Expatriation with Offshore Disclosures – Helping individuals who want to relinquish their green card or renounce U.S. citizens expatriate in a tax efficient and compliant manner
Full voluntary disclosures – Although the Offshore Voluntary Disclosure Program (OVDP) ended in 2018, we continue to make voluntary disclosures to IRS counsel for clients with significant tax and/or criminal exposure who otherwise do not qualify for the Streamlined Procedures
TAX CONTROVERSIES AND RESOLUTIONS
We assist clients with the resolution of issues resulting from federal and state tax return examinations. Our tax professionals have over 20 years of combined experience dealing with wide range of federal and state tax issues for both individuals and business entities. We understand the tax law and we can assist you with:
Federal and State Examinations – Representation before IRS or state tax authorities from the beginning to the end, including analysis and technical research supporting tax positions.
Appeals – preparation of tax protest and representation at IRS Appeals Office or state tax appellate authority.
Our team has extensive experience drafting and reviewing trusts and wills for US clients and foreign clients with exposure to US gift and or estate tax through the ownership of US-situs assets and/or the desire to benefit US persons.
We also advise private and institutional trustees on the management of assets and compliance with their fiduciary duties. Our goal is to ensure that trusts are run in an efficient manner that adheres to the needs of settlors and beneficiaries. In this process, we certify that trusts and their trustees are following their own particular tax and reporting obligations and to advise beneficiaries and settlors of foreign trusts who may be subject to a unique set of income, estate, and gift tax rules specific to foreign trusts with US touchpoints.