Practice Areas

Representative Clients

Within our Tax Group, the demographic of our clients varies greatly and reflects Teeple Hall, LLP’s established and recognized leadership in the area of Tax.
 

  • Individuals

  • Business Owners

  • Professionals

  • HNW Families – US

  • HNW/UHNW Families - International

  • Family Offices

  • Trust Companies

  • Private Banks

  • Insurance Companies

  • Legal/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.    

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.

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. Estate & Gift Tax Planning, Audit and Controversy

  • 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.

  • U.S. Inbound Income and Estate Tax Planning

  • Planning for U.S. inbound investment

  • Planning for U.S. inbound wealth transfers

  • Pre-immigration income and estate tax planning

  • U.S. Outbound Income and Estate Tax Planning

  • U.S. income and estate tax planning 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

  • U.S. foreign reporting compliance for U.S. individuals, companies and trusts with  foreign assets (financial and non-financial), entities and trusts

  • 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

  • Advice and counsel on implications of involuntary loss of a Green Card

  • FATCA and CRS Advisory

Tax Group

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.
     

  • 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 artist on a successful OVDP submission.
     

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

  • 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.

 
 

Teeple Hall, LLP

9255 Towne Centre Drive, Suite 500

San Diego, CA 92121 USA

+1 858.622.7878 main

+1 858.622.0411 fax

www.teeplehall.com

Disclosures

© 2021 by TEEPLE HALL, LLP.