Tax representation of U.S. and foreign owned business enterprises in cross border business transactions, acquisitions, financings, corporate restructurings, export and overseas distribution, IC DISC formation and operation, and manufacturing operations, transfer pricing audits, consulting on international aspecto of the Tax Cuts and Jobs Acts 2017 (TCJA) including GILTI and FDII planning and compliance.
Private Clients and Multinational Families
Representation of private clients including multinational families in family business succession, use of foreign and domestic trusts, wealth transfer planning, economic emigration, pre-immigration and expatiations and protection of assets against future creditor claims.
Tax Controversies, Rulings and Disclosures
Representation of individuals and business organizations in international tax compliance and foreign financial accounts disclosures. Representation of individual clients before the IRS and State tax authorities in ruling requests, advance pricing agreements, audits, of international tax issues including transfer pricing issues, administrative appeals and court cases.
Non-Residents and Foreign Owned Businesses
Tax representation of nonresident individuals and foreign enterprises with U.S. business and real estate acquisitions with respect to establishments, operations, restructurings, and liquidations.