Millett Rafferty
Attorneys at Law

Tom's Practice

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