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—
I have handled hundreds of foreign accounts compliance cases.
I provide counsel on expatriation from the United States. This includes—
Civil Tax Controversies.
Throughout my career I have represented taxpayers in civil tax controversies, including—
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.
Throughout my career I have planned estates. In planning my clients’ estates, I—
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.
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.
Guardianships and Conservatorships.
I provide counsel on guardianships and conservatorships.