We specialize in US tax law for nonresidents, foreign investors, and foreign businesses.
“The art of taxation consists in so plucking the goose as to obtain the largest possible amount of feathers with the smallest possible amount of hissing.”
When more than one country is plucking your goose, we can help.
Ready, aim, shoot is a good strategy in many situations, but rarely does it work well for taxes. When money moves across a border you need to be thinking about taxes. And even if the movement of money across a border is tax-free, there is often paperwork involved. Forms to file. Things to declare. With staggering penalties if you don’t do the paperwork.
Paperwork, forms, and penalties: wreckage of the past, wreckage of the future
The U.S. tax system is built on the notion that every action must be reported to the tax authorities. Your basic assumption should be “There’s a form for that.” Filing the form late or not at all usually causes a penalty. In the international tax arena the penalties are sometimes life-altering in size. The tax system is built as if every parking ticket you get results in confiscation of your car.
This means that our clients need guidance on what to do — checklists, operational support to their financial advisors and accountants, and in some cases outright outsourcing — to keep out of trouble.
We work as outside advisors to our clients’ accountants, CFOs, and other professionals to make sure that the required forms are filed, and that they are filed correctly. In some cases our clients outsource the international tax paperwork to us, because we live in this world every day.
In other words, we prevent wreckage in your future.
We also clean up the wreckage in of the past. Big errors and small — there are massive penalties waiting for you, even if the errors are accidental or innocent.
- Unreported offshore financial accounts? We’ve advised hundreds of people in this situation.
- What happens when your company has not filed Form 5471 for its foreign subsidiaries? There’s a $10,000 penalty for that. We work with U.S. businesses with international operations, to identify and clean up prior tax problems.
- What happens if the right forms have not been filed for a foreign trust or an inheritance from a nonresident? We create, manage, revise, and terminate foreign trusts. We migrate trusts to the United States. We handle the tax impact of foreign trusts on the beneficiaries living in the United States. This can affect even the retired schoolteacher who owns a condominium in Mexico–she faces catastrophic penalties if she has not filed Form 3520, for instance.
U. S. real estate investments by nonresidents
We handle a lot of real estate transactions for nonresidents. We help with the legal and business aspects of the transaction, as well as the tax planning. Personal residences, investment properties, business and industrial property. We know FIRPTA.
U. S. taxation of foreign corporations
This is what tax lawyers call “inbound” taxation. Businesses from abroad decide to do business in the United States. How do they configure their business operations to minimize worldwide tax?
Expatriation
For those who wish to give up their U.S. citizenship or their permanent resident visa status (the so-called “green card” visa) we help them all the way through termination of their immigration or citizenship status. Then we get them properly and legally out of the U.S. tax system. For the many people who gave up their green cards but never “logged out” of the U.S. tax system, we help them do that. (Yes, it is possible for you to give up your passport or your green card but still be a U.S. taxpayer.)