Services

Tax Compliance

  • Gift Tax (Form 709)
  • Foreign-Owned LLC (Form 5472)

Tax Controversy

  • Streamlined filing compliance procedures
  • Delinquent international returns
  • Delinquent FBAR submissions

International Taxation

  • Tax treaty analysis
  • Cross-border transfer pricing
  • Controlled foreign corporation (CFC) disclosure (Form 5471)
  • Passive foreign investment company (PFIC) disclosure (Form 8621)
  • Foreign disregarded entity (Form 8858)
  • Foreign trust & gift (Form 3520)

Entity Selection & Structure

  • Choice of U.S. vs non-U.S. jurisdiction
  • Entity selection (LLC, Corp, LP, Trust)
  • Entity Classification Election (Form 8832)
  • S Corporation Election (Form 2553)
  • Holding company structures

Tax Policy Research

  • Review impact of pending federal, state & international legislative changes
  • Statutory & regulatory analysis
  • Review compliance & enforcement trends
  • Case law review

Tax Advisory

  • Tax planning solutions for individuals and businesses to minimize overall impact on income, sales, excise & wealth taxes
  • M&A tax planning solutions for the sale or purchase of an existing business
  • Provide estate & wealth transfer strategies for high-net worth individuals