Experience

Advised high-net-worth individuals and families on pre-immigration tax planning, including foreign entities, PFICs, and foreign trusts.

Counseled long-term U.S. residents and citizens on expatriation, including covered expatriate analysis and exit tax planning.

Advised U.S. citizens abroad on investment structuring, PFIC planning, Net Investment Income Tax, and Form 8621 compliance.

Counseled U.S. citizens relocating to Europe on business restructuring, permanent establishment risk, compensation planning, and dual-filing compliance.

Analyzed French and Spanish usufruct arrangements for U.S. gift and estate tax implications and trust planning.

Advised on cross-border life insurance and ILIT structures for non-U.S. clients with U.S.-situs assets.

Counseled non-resident alien clients on U.S. estate tax exposure, Form 706-NA compliance, and IRS transfer certificate procedures.

Structured U.S. real estate investments for non-U.S. persons using foreign holding companies and U.S. entities, addressing FIRPTA, transfer tax exposure, and treaty planning.

Advised a Mexican corporation on restructuring a U.S. real property holding corporation (USRPHC), including FIRPTA, Section 1445, and cross-border financing.

Structured U.S. real estate holdings for a foreign investor acquiring multiple Miami properties through foreign holding companies and U.S. LLCs.

Advised on cross-border business restructuring, entity planning, treaty coordination, and international tax considerations for individuals and closely held businesses.

Guided taxpayers through the IRS Streamlined Filing Compliance Procedures and Voluntary Disclosure Program.

Advised on FATCA status determinations, GIIN registration, and W-8 documentation for foreign financial institutions and family offices.

Represented the heirs of a Latin American decedent in a Florida probate involving U.S. real estate, multiple foreign beneficiaries, estate tax filings, and coordination with parallel foreign proceedings.