Client Solutions — Tax
Case Study – 90% Reduction in U.S. income tax liability
When the owner of a California-based financial services company sought to reduce his corporate and personal tax liability, we proposed some of the options available in Puerto Rico and the U.S. Virgin Islands. We provided guidance about each jurisdiction’s relative tax benefits, as well as the practicalities of relocating there with his family. After his decision to relocate to the U.S. Virgin Islands, we prepared his tax exemption application, represented him at the public hearing on the application, and obtained the approval of the USVI Economic Development Commission, thus reducing his U.S. income tax liability by approximately 90%.
Case Study – IRS Interest Penalty Resolution
Our tax attorneys were approached by an elderly client who had received an inheritance many years ago in the form of a valuable bank account in Switzerland. Her prior tax advisor had reported the income from the account during an audit, and she was unaware of any reporting obligations to the IRS, so our client had never filed the required Foreign Bank Account Report (FBAR) to disclose the existence of the account. We successfully resolved all of the relevant reporting requirements and no interest or penalties were assessed against the client.
Case Study – Avoided U.S. Estate & Gift Tax
Our tax planning attorneys were approached by the adult American-citizen children of a wealthy Spaniard who had created an elaborate offshore holding structure for his now substantially appreciated U.S. stock portfolio. We assisted the clients by devising a plan to dismantle the offshore structure while making gifts of the stock portfolio, and a substantial amount of cash, to the children. Our plan successfully avoided all potential U.S. estate and gift taxes and it permitted the children to receive the stocks in the portfolio while simultaneously minimizing their exposure to potential future capital gains taxes.
Case Study – U.S. Entity Formation Consulting
Our tax planning attorneys consulted with an Australian company which provides review and opinions on financial models. To service its U.S. clientele, the company was seeking to establish a U.S. entity in a tax-efficient manner. We explained the differences in taxation involving the available choices of entity and jurisdiction, then formed the entity, obtained a taxpayer ID number, and registered the business with state and federal tax authorities.
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