Our Services

The aptly-named Blue Water Bridge, connecting Port Huron, Michigan and Sarnia, Ontario. The north span, on the left, is the original bridge. The south span, on the right, was added in the 1990s. Looking north from the Blue Water Bridge onto Lake Huron is one of the most spectacular views I have ever seen.

Foreign Accounts Compliance

I help citizens and lawful permanent residents comply with U.S. laws concerning foreign income, accounts, and entities. I file delinquent FinCEN Forms 114a, Report of Foreign Bank and Financial Accounts (“FBARs”). I make submissions under the Internal Revenue Service’s Delinquent International Information Return Submission Procedures as well as its Streamlined Procedures, for residents of the United States as well as nonresidents. Matters I commonly encounter include—

Foreign trusts and Forms 3520 and 3520-A.
Foreign corporations and Form 5471
Foreign entity classification for U.S. income tax purposes.
Personal foreign investment companies (”PFICs”) (foreign mutual funds).
Controlled foreign corporations (“CFCs”).
Analysis and application of bilateral income tax treaties between the United States and foreign countries, and reporting on Forms 8833.
United Kingdom self-invested pension plans (“SIPPs”).
Canadian registered retirement savings plans (“RRSPs”), registered retirement income funds (“RRIFs”), and tax-free savings accounts (“TFSAs”).
Singapore Central Provident Fund Accounts

I have handled hundreds of foreign accounts compliance cases.

Photo Credit: @Lorem Ipsum

Expatriation

I provide counsel on expatriation from the United States. This includes—

Renouncing U.S. citizenship
Abandoning U.S. lawful permanent resident (“green card”) status.
Completing Form 8854.
Advising covered expatriates, including analysis of U.S. bilateral income tax treaties as needed.

Civil Tax Controversies.

Throughout my career I have represented taxpayers in civil tax controversies, including—

1 Federal tax assessment cases
2 Federal tax collection cases, including offers in compromise, currently not collectible postings, and installment agreements.
3 Matters before the Internal Revenue Service Appeals Office.
4 Litigation in trial and appellate courts of the United States.

Criminal Tax Prosecutions.

Throughout my career I have represented taxpayers in criminal tax investigations and prosecutions. This includes technical analysis, voluntary disclosures, counsel concerning grand jury testimony, pretrial motions, and representation at trial and on appeal.

Estate Planning.

Throughout my career I have planned estates. In planning my clients’ estates, I—

1 Make sure their property goes to the persons they want it to go to, with a minimum of tax upon succession to their property; and
2 Avoid probate upon succession to their property.

I draft documents to accomplish clients’ dispositive intentions, and supervise execution of the documents. I fund clients’ trusts, and confirm beneficiary designations on clients’ retirements and life insurance policies. I avoid the gimmickry and conflicts of interest common in high-end estate planning.

Photo Credit: @Lorem Ipsum

Estate Administration.

I administer decedents’ estates, collecting assets and distributing them. I provide counsel on administration of trusts. I prepare Federal estate tax returns. I review income tax returns of trusts and estates.

Photo Credit: @Lorem Ipsum

Guardianships and Conservatorships.

I provide counsel on guardianships and conservatorships.