We have over 35 years of  experience helping clients solve problems.

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Dual Nationals and Expatriates

• We understand the particular problems that dual nationals and expatriates face with taxation in multiple jurisdictions, reporting and disclosure issue  and family wealth and succession planning.
• We work with individuals in solving disclosure and reporting  problems regarding offshore assets, whether they arise from family inheritance, gifts or assets owned.  Such problems include how to report gifts and minimize or avoid penalties; how to report offshore trusts; how to report interests in offshore family businesses.
• We help clients understand the implications of tax treaties and information exchange agreements.
• We assist clients in determining if expatriation is a proper option.

International Business Planning:
How should you set up your international business?

• Are there tax advantages or business advantages that should be considered.
• What is the most tax effective jurisdiction for your foreign business?  Do you have a Controlled Foreign Corporation or Controlled Foreign Partnership?
• Do you have to report foreign financial accounts?  What are the proper compliance steps that you should take?
• Can you keep profits offshore and minimize income tax?
• These and other decisions are very important in planning and operating your business.

Domestic business planning:

• We help you sort through the choice of entity decisions.  Should you form a general or limited partnership or  incorporate, or form an LLC?  Should you make or terminate an “S” election?
• What are the tax and other advantages and disadvantages of each entity choice  and which could work best for you?
• How should you hold your business interests, individually, as husband and wife, in a living trust, or irrevocable trust, and what about a family limited partnership?
• Which of these choices should you make?

Succession Planning:
Whether it is through buy-sell planning, including the use of life insurance, or a business sale, a mergers or a liquidation, we can help you plan to minimize taxes.

Divorce Taxation:

• Do you have to sell assets to fund the divorce or bust up pension plans?  Proper tax analysis is very important.
• Do you have the right to claim that you are an innocent spouse?

Tax Disputes and Audits:
Do you have an audit of your business or personal tax returns?  If so, we can help you navigate “eggshell audits.

IRS and FTB:
Audit planning and compliance with audit document information requests is very important to successful results.

• Are there issues of unreported income or overstated deductions, if so a voluntary disclosure may be important for you.
• Do you have unfilled income tax returns or gift tax returns, such as unfilled income tax returns, controlled foreign corporation returns, foreign gift or foreign trust returns?
  
• Should you file late returns or  amended returns?
• Do you have Fifth Amendment issues to consider?

Penalties:
Do you have grounds for penalty abatement requests?

• Why was a penalty assessed
• Is  there a reasonable cause  basis for waiver   of the penalties?

FBAR and Information Return Penalties:
Have you failed to file foreign bank account reports or other information returns?

• There are serious civil and criminal penalties for failure to timely report interests held in foreign financial accounts.

Tax Fraud:
Are you facing a civil fraud penalty?  What can be done?

Sales Tax:
If you operate a traditional brick and mortar business or an Internet business sales tax is an important issue.

• Are you timely collecting and paying over the proper tax on all taxable items?   If not, are you facing a personal liability?
• Have you properly determined that some of your sales  are exempt?

Tax Appeals:
Do you have the basis to contest a proposed assessment as a result of an audit?  We have handled hundreds of protests, and Tax Court Petitions.

Cancellation of Debt:
Did you go through a foreclosure or make a “short sale”?  If so, you will likely receive a Form 1099-C from your lender for the amount of the forgiven debt.  Were you insolvent at the time the debt was forgiven, if so, you may be able to avoid the tax on the forgiven debt.

Payroll Tax Assessments:
Do you have a payroll tax liability?  Have you been personally assessed?  Are you the real responsible person?  What are you options?

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We can help. Get in touch today.