We offer advisory and consulting services in:

• Commencement or restructuring of operations and investments in the United States for U.S. citizens and residents, legal entities and foreign trusts.

• Commencement or restructuring of investments and operations outside the United States for U.S. citizens and residents, U.S. entities and trusts.

• Analysis and application of treaties for the avoidance of double taxation in transnational transactions

• Corporate reorganizations and restructurings with international components, such as mergers, acquisitions, spin-offs, and liquidations

• Tax compliance issues, including:
  • Due diligence
  • FATCA (Foreign Account Tax Compliance Act)
  • FIRPTA (Foreign Investment in Real Property Tax Act)
  • Preparation and processing of processes with the United States Internal Revenue Service (IRS) for the normalization of assets including, but not limited to:
    – Criminal Investigation Voluntary Disclosure Practice
    – Delinquent International Information Return Submission Procedures
    – Streamlined Filing Compliance Procedures
  • Corporate Transparency Act

• Creation and administration of Trusts

• Expatriation

• Formation and maintenance of domestic and international business structures.

• Tax planning process prior to migration to the U.S.

• National and international estate planning process, including advice and document preparation

• Cross-border transactions