Our Experience

Transaction Planning

We advised US and foreign investors on income tax and transfer tax strategies in a multi-billion-dollar acquisition with initial investments having grown 100X. We also advised entrepreneurs on pre-sale and pre-IPO strategies.

Preimmigration and Expatriation Planning

We counseled Asian and Middle Eastern families on preimmigration planning strategies focusing on overseas businesses and assets. We also counseled US citizens and green card holders on “exit tax” planning and remedying previous non-compliance issues.

Trust Planning

We developed transfer tax strategies using, for example, sale to grantor trust structures, US foreign grantor trust structures, and US foreign non-grantor trust structures for families with both US and overseas business interests and assets, and we coordinated with local attorneys and advisers for effective implementation and compliance with all the relevant jurisdictions.

Tax Compliance and IRS International Penalty

For our tax compliance services, we counseled and represented clients in IRS voluntary disclosure programs for correcting previous non-compliance issues, where the previously-undisclosed foreign businesses and foreign assets ranged from one hundred thousand dollars to over one hundred million dollars in countries including China, Hong Kong, Singapore, Switzerland, Taiwan, and the UAE.

We also represented clients who have been subject to IRS international penalties, where we resolved penalties over a million dollars asserted on international information returns such as Form 3520, Form 5472, and Form 5471.