Domestic Planning and Engagements
Income
Tax, Investment and Business
Investor and business owner tax and business planning for ongoing
operations
Private
equity and angel investment structuring, tax planning & documentation
Purchase and
sale tax allocations, partnership tax basis step-ups
Business restructuring and liquidations
Investor &
director planning & risk management
State income tax residency status changes and challenges
Estate Planning & Estate Tax Planning
Federal and
Massachusetts estate tax
Gift and
generation skipping tax - long term trusts
Planning
for non-resident ownership of Massachusetts estate taxable assets
Private trustee & estate
representative for client families
Cross-Border Tax Planning and Engagements
Inbound
Taxation of Foreign Investors
Investment
in U.S. real estate by foreign nationals - income and estate tax planning, securing
interest deduction on financings, S. 879
ECI elections, FIRPTA withholding
Planning
for change in tax residency status, pre-immigration tax planning, treatment of dual
status, treaty tiebreakers, joint return issues
Foreign
business expansion into U.S. market, choice of entity, debt versus equity,
withholding issues
US partnership withholding on nonresident partners
Outbound
Investment and Foreign Income of US Citizens
Planning,
elections, disclosures and & reporting for foreign: accounts, specified
financial assets, passive investment companies, corporations, disregarded
entities
Foreign tax credit planning, tax treaty re-sourcing of income
U.S. taxation of citizens abroad, earned income
exclusion
Tax Controversies
IRS
Office of Appeals representation, offers in compromise, installment agreements,
federal tax liens
