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Tax

Practice Areas
Team
Representative Clients

  • Individuals

  • Business Owners

  • Professionals

  • HNW Individuals and Families (U.S. and International)

  • Family Offices

  • Trust Companies

  • Private Banks

  • Insurance Companies

  • Law Firms

  • Accounting Firms

The Tax Group provides unparalleled representation across a broad spectrum of situations including tax planning, tax reporting and compliance, voluntary disclosure, audit and tax controversy on both a domestic and international level.    

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For more than 25 years, the Firm has been mindful and diligent that “tax touches every element of life and business” and that a strong Tax Group is a foundational element for the Firm in delivering exceptional representation for our clients. Coupled with the Firm’s experience, commitment, and dedication to the resolution of complex tax situations, our attorneys deliver strong and principled advice on specific tax issues including (i) income tax planning, (ii) estate and gift tax planning, (iii) international tax planning (U.S. inbound and U.S. outbound), and (iv) tax reporting and compliance matters involving U.S. disclosure of foreign assets, trusts, and entities.  
 
The Firm’s attorneys bring a vast array of experience from backgrounds including key positions with the IRS and Treasury Department, professorial positions with leading educational institutions and global consulting and advisory firms. The Group approaches tax cases with a deep breadth of knowledge, enthusiasm, and a zeal for assertive and ethical representation.

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Within the Tax Group, the Firm is involved in a wide range of tax planning and tax controversy matters including:

 

  • U.S. and State Income Tax Planning, Audit and Controversy (U.S. Inbound and Outbound)

  • U.S. Estate & Gift Tax Planning, Audit and Controversy (U.S. Inbound and Outbound)

  • International Income Tax Planning

  • Corporate transactions (Inbound and Outbound)

  • M&A advising and consulting

  • Tax planning for foreign operations of U.S. based companies

  • Tax planning for U.S. operations and activities of foreign individuals and companies

  • Planning for U.S. inbound investment

  • Planning for U.S. inbound wealth transfers

  • Pre-immigration income and estate tax planning

  • U.S. income and estate tax planning and foreign reporting for U.S. individuals, companies and trusts with foreign assets, entities and trusts

  • Planning for foreign-source income and coordination with local counsel on local country tax issues

  • U.S. Foreign Reporting and Tax Compliance

  • Offshore voluntary disclosure for U.S. Persons with undeclared foreign entities, trusts, and financial assets

  • Expatriation Planning including

    • Planning for expatriation on relinquishment of U.S. citizenship including planning and strategy to avoid/minimize “covered expatriate” status under IRC 877A

    • Planning for relinquishment of U.S. permanent resident status including planning and strategy to avoid/minimize “covered expatriate” status under IRC 877A

  • FATCA and CRS Advisory

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Representative Matters

Tax Group representative matters reflect the diversity of the Firm and Practice Groups and the wide range of tax transactions, tax planning, and tax controversy cases on which we advise.  

 

  • Represented a California non-profit association through audit on substantial issues, including self-dealing transactions, which threatened the entity’s tax-exempt status and obtained a no-action ruling on the audit.
     

  • Counseled a high-profile individual who served as a director on a NYSE listed company on SEC reporting violations and foreign tax disclosure violations by successfully entering the client into the IRS Offshore Voluntary Disclosure Program. The Firm also handled the case through an audit of the OVDP process and obtained a multi-million-dollar income tax refund.
     

  • Advised a high-profile individual facing potential disclosure by their foreign financial institution on a successful OVDP submission.

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  • Successfully obtained IRS CID clearance and processed a voluntary disclosure filing for a client facing imminent discovery by the IRS, criminal prosecution and reporting penalties in excess of 150% of the value of the client’s foreign assets.

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  • Advised a U.S. inbound family on pre-immigration tax planning for the ownership and contemplated sale of a privately owned business operated in their home country.  The Firm managed the client’s immigration plans and coordinated and advised the home country’s legal and tax professionals, working to step-up the basis on the client’s operating company and avoid U.S. capital gains tax on a $20 million valuation of the company.  
     

  • Advised an UHNW family on pre-immigration tax and estate planning for a large portfolio of diverse assets including high-profile interests in several media projects.  The project involved extensive coordination with the Client’s advisors in multiple jurisdictions.
     

  • Advised a U.S inbound individual on pre-immigration tax planning focused on both U.S. estate tax planning and, crucially, tax basis step-up planning and analysis on highly appreciated marketable and non-marketable securities, resulting in the recognition of substantial gain (in excess of $40 million) on the Client’s assets prior to obtaining U.S. Person status.

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