Foreign Accounts Compliance

We have assisted hundreds of clients in complying with United States laws concerning foreign accounts, income, assets, and entities.  We avoid or minimize penalties incurred by clients in becoming compliant.  Our services include—

  • Delinquent FBAR Submission Procedures
  • Delinquent International Information Return Submission Procedures, for submission delinquent international information returns, including—
  • Form 8938
  • Form 3520
  • Form 3520-A
  • Form 8621
  • Form 5471
  • Form 8865
  • Streamlined Compliance Procedures for Residents of the United States
  • Streamlined Compliance Procedures for Nonresidents of the United States
  • Voluntary Disclosure Practice

We contest penalties assessed or proposed against our clients for failure to timely file international information returns.

International Taxation

We advise clients on United States income taxation of inbound as well as outbound transactions.

We analyze United States bilateral tax treaties, and advise clients on same.

We advise clients on United States withholding taxes and tax reporting on international transactions.

Tax Controversies

We represent individuals and entities in Federal and State tax controversies, including audits, collection cases, appeals, and litigation.

We represent defendants in criminal tax investigations and prosecutions through trial and, if necessary, appeal.

Estate Planning and Administration

We assist our clients in accomplishing their estate planning objectives, including—

  • Making sure clients’ property goes to the persons they want it to go to.
  • Minimizing taxes on succession to clients’ property, and deferring such taxes for as long as possible.
  • Avoiding probate proceedings on succession to clients’ property.

Estate planning documents we draft for clients include—

  • Revocable (“living”) trusts
  • Wills
  • General durable powers of attorney
  • Health care durable powers of attorney
  • Irrevocable trusts
  • Special needs trusts

We fund clients’ trusts.  We update beneficiary designations on clients’ life insurance policies and retirement plan interests.

We administer clients’ estates.

We represent clients in probate court proceedings, including estate administration proceedings, guardianship proceedings, and conservatorship proceedings

Prenuptial Agreements

We counsel clients on prenuptial agreements, and draft prenuptial agreements.

Corporate Documents

We prepare corporate documents as needed for clients, including documents to form corporations, reorganize corporations, divide corporations, and liquidate corporations. 

We prepare shareholder agreements for closely-held corporations.