International Taxation

1. U.S. citizens, green card holders, and residents must report foreign bank accounts, investments, companies, and trusts on the FBAR and on information returns such as Forms 8938, 3520, and 5471, with substantial penalties for omissions. We help clients determine what must be reported, bring their filings current, and respond to IRS inquiries concerning foreign holdings.

1. Becoming a U.S. tax resident subjects worldwide income and assets to U.S. taxation, and giving up a green card or citizenship may trigger an exit tax. We advise clients before they move, before they obtain permanent residence, and before they expatriate, on timing, asset restructuring, and the elections available to reduce the tax consequences of the change in status.

The United States has income tax treaties with the United Kingdom, Ireland, and Türkiye, among many others, and estate tax treaties with a smaller group of countries. We advise on treaty residence tie-breakers, reduced withholding on dividends, interest, and royalties, foreign tax credits, and the treaty positions that must be disclosed on a U.S. return.

Inheritances from abroad, gifts from foreign relatives, and U.S. assets owned by non-residents each carry their own reporting and tax rules. We advise on the U.S. estate and gift tax exposure of non-resident owners of U.S. real estate and securities, the reporting of foreign gifts and bequests, and the coordination of a U.S. estate plan with succession rules in another country.

Ownership of a foreign trust, a foreign corporation, or a foreign investment fund can produce unexpected U.S. consequences, including controlled foreign corporation, passive foreign investment company, and foreign trust throwback rules. We analyze existing structures, advise on their U.S. treatment, and assist with restructuring where the current arrangement creates avoidable tax or reporting burdens.

Clients who learn that prior returns omitted foreign income or assets have several paths to compliance, including the Streamlined Filing Compliance Procedures, delinquent information return submissions, and the IRS Voluntary Disclosure Practice. We evaluate which program fits the facts, prepare the required certifications and narratives, and negotiate penalty relief where reasonable cause exists.

We regularly assist Turkish, British, and Irish individuals and businesses with U.S. real estate purchases, investments, business formation, and relocation, including obtaining taxpayer identification numbers, FIRPTA withholding on real estate sales, state tax residency questions in New Jersey, New York, and Florida, and the U.S. treatment of income and assets that remain at home.

We advise individuals, businesses, investors, and fiduciaries on U.S. economic sanctions administered by the Office of Foreign Assets Control (OFAC). Our services include sanctions screening, evaluating cross-border transactions and ownership structures, advising on blocked assets and restricted dealings, and assisting with licensing requests and compliance concerns. We help clients address sanctions considerations alongside international tax planning, foreign investments, business transactions, and estate and trust administration.