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U.S. Persons and Entities 

 

 

  • Full spectrum of U.S. income and capital gains tax matters, taking into account issues such as 

    • Foreign entities & CFC related matters

      • 965 repatriation and FTC matters

      • 951A GILTI matters & FTC planning

      • Subpart F

      • Attribution 

    • Marital status and related matters

    • IRC 911 

    • Tax Treaties

    • US Social Security liability

  • Estate and gift planning

    • Residency and domicile​

    • Spousal status and related matters

  • Expatriation (citizens and LTR), exit tax and related penalties

    • IRC sections such as 877A, 2104 and 2801

  • FBAR/FATCA

  • PFIC and pension issues 

  • Advisory services for wealth management, including generational planning, trusts and philanthropy.  

We offer innovative, cost effective and end to end solutions addressing U.S. and non-U.S. local law. 

 

Non-U.S. Persons and Entities

  

  • Federal and state income and capital gains tax as is related to:

    • Investment in U.S. real estate (FIRPTA). 

    • U.S. business activity of foreign companies, taking into account issues of PE, ECI & Tax Treaties.

    • Non-U.S. partners of businesses with U.S. presence.  

    • Relocation issues into or out of the U.S.

  • Advanced estate/gift tax solutions for: 

    • Existing and prospective investments in U.S. real estate and other US situs assets.

    • non-U.S. partners of business with U.S. ECI.

    • Generational transitions and strategies.

    • Sudden death and Form 706 planning and opinions.

    • Pre-Immigration/relocation tax planning.  

  • Advisory services for wealth management, including generational planning, trusts and philanthropy.  

 

 

We offer innovative, cost effective and end to end solutions addressing U.S. and non-U.S. local law.