Experience

Structured U.S. real estate investments for non-U.S. persons and families using two-tiered foreign corporation and U.S. entity structures, addressing FIRPTA withholding, transfer tax exposure, and treaty planning.

Advised high-net-worth individuals and families on pre-immigration tax planning, including restructuring of foreign entities, PFIC holdings, and foreign trusts prior to establishing U.S. tax residency.

Counseled long-term U.S. residents and citizens on expatriation, including covered expatriate analysis, exit tax modeling under Section 877A, and deferred compensation planning.

Guided non-willful and willful taxpayers through the IRS Streamlined Filing Compliance Procedures and Voluntary Disclosure Program, achieving penalty-free or substantially reduced outcomes.

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

Counseled non-resident alien clients on U.S. estate tax exposure for U.S.-situs assets, including LLC interest classification, Form 706-NA compliance, and IRS transfer certificate procedures.

Analyzed usufruct arrangements established under French and Spanish civil law, advising on IRC §2036 retained interest risks, gift and estate tax treatment, and coordination with U.S. trust and estate planning structures.

Advised U.S. citizens abroad on investment portfolio structuring to avoid PFIC classification, Net Investment Income Tax exposure, and ongoing Form 8621 compliance obligations.

Counseled U.S. citizens relocating to Europe on business restructuring, permanent establishment risk, W-2 compensation planning, social security totalization, and dual-filing compliance.

Advised on cross-border life insurance and ILIT structuring for NRA clients with U.S.-situs assets, addressing estate tax liquidity, cross-border trust administration, and treaty coordination.

Advised the heirs of a Latin American decedent in a Florida probate proceeding involving U.S.-situs real estate, multiple non-U.S. beneficiaries, and a parallel estate proceeding in a foreign jurisdiction. Coordinated international service of process, prepared the estate tax return, and counseled on the U.S. income tax consequences of post-death transfers of U.S. real property among non-resident alien heirs.

Advised a Mexican corporation holding a U.S. real property holding corporation (USRPHC) that owned high-value Miami residential real estate on the U.S. tax consequences of proposed restructuring options, including analysis of FIRPTA withholding obligations on capital contributions and membership interest transfers, evaluation of IRC nonrecognition provisions and applicable exceptions under Section 1445, and structuring of a third-country intermediary financing arrangement to address cross-border fund transfer restrictions.

Structured U.S. real estate holdings for a foreign investor acquiring multiple Miami residential properties through a tiered structure consisting of a foreign holding company and U.S. LLCs, advising on FIRPTA exposure, U.S.-situs asset classification, entity formation, and ongoing income tax and compliance obligations — with counseling conducted in French and Spanish