Practice Areas
TAX CONTROVERSIES
The firm handles tax controversy matters at all levels with the Internal Revenue Service relating to international tax matters, including initial audits, examinations and investigations, administrative protests and appeals, requests for private letter rulings and United States Tax Court proceedings.
REMEDIAL IRS COMPLIANCE AND "JOHN DOE" SUMMONSES
The firm has extensive experience in handling remedial IRS compliance for non-compliant taxpayers, including delinquent filings and voluntary disclosures to appropriate tax authorities. The firm has represented a number of US individuals in connection with "John Doe" summonses issued to offshore financial institutions.
FIRPTA PLANNING—FOREIGN INVESTMENT IN U.S. REAL ESTATE
The firm provides advice to foreign investors regarding the structuring and disposition of investments in real property located in the United States. Issues include taxation and withholding under the Foreign Investment in Real Property Tax Act of 1980 (FIRPTA), as well as U.S. estate and gift tax implications.
CROSS BORDER ACQUISITIONS, DISPOSITIONS & REORGANIZATIONS
The firms advises U.S and foreign clients relating to the cross-border acquisition, disposition and restructuring of businesses, including tax-free reorganizations.
OUTBOUND TAX PLANNING: FOREIGN BUSINESS OPERATIONS & INVESTMENTS OF U.S. PERSONS
The firm provides advice to U.S. individuals and businesses establishing operations or investments outside the U.S. We have extensive experience with the potential impact of the complex tax rules relating to controlled foreign corporations and passive foreign investment companies.
The firm regularly advises clients regarding entity selection, joint ventures and contractual matters in order to maximize tax deferral opportunities and minimize overall effective tax rates, in addition to compliance with tax reporting rules. As part of our practice, we have extensive experience in the use of hybrid and “check-the-box” entities.
INBOUND TAX PLANNING: INVESTMENTS & BUSINESS OPERATIONS OF FOREIGN PERSONS IN THE U.S.
Foreign corporations, individuals or investment funds seeking to conduct business or investment activities in the U.S. must consider the implication of a myriad of U.S. tax rules and regulations that may subject the foreign entity or individual to U.S. income and withholding taxes upon current operations and exit. The firm advises foreign clients with respect to U.S. income issues, including effectively connected income rules, earnings stripping rules, portfolio interest and branch profits.
TAX TREATY PLANNING
The firm advises clients on structuring and planning to maximize benefits under applicable United State tax treaties in order to minimize overall combined U.S. and foreign taxes.