Our Tax Practice provides sophisticated and comprehensive counsel on U.S. and international tax matters for high-net-worth individuals, family offices, multinational businesses, and fiduciaries. We deliver practical, tailored strategies that navigate the complex intersection of domestic tax laws, cross-border regulations, and evolving global transparency standards.

We regularly advise on:

International Tax Planning and Compliance

Our team is deeply experienced in guiding foreign individuals and multinational corporations through the intricacies of the U.S. tax system. We advise on inbound and outbound structures, tax treaty interpretation, FIRPTA, FATCA/CRS compliance, and the use of U.S. and offshore entities to optimize global tax efficiency.

• Structuring cross-border investments into U.S. real estate, private equity, and operating businesses
• Formation and administration of offshore companies, trusts, and private interest foundations
• Planning for the application of Subpart F, GILTI, PFIC, and CFC rules
• Analysis of treaty benefits, including portfolio interest exemptions and withholding tax reductions

Corporate Reorganizations and Business Tax Structuring

We represent domestic and foreign business entities in connection with mergers, acquisitions, spin-offs, inversions, and entity reorganizations across borders. Our goal is to align tax efficiency with legal risk mitigation and operational needs.

• Corporate restructuring and holding company formations (onshore and offshore)
• Tax-efficient exit planning and capital repatriation
• Advising on choice-of-entity and U.S. tax classification elections
• U.S. tax planning for multinational subsidiaries and joint ventures

IRS Compliance, Tax Controversy & Appeals

Our team represents clients in high-stakes IRS matters, including audits, administrative appeals, and litigation before the U.S. Tax Court and other federal tribunals. We also advise on voluntary disclosures, penalty abatement, and compliance with complex reporting requirements.

• IRS audits and examinations (individual, corporate, trust, estate)
• Tax Court and administrative appeals representation
• Defense in FBAR, Form 5471/3520/8938 reporting penalty matters
• Offers in compromise and collection due process hearings

Estate Planning, Probate & International Succession

We design and implement estate plans for clients with U.S. and non-U.S. assets, addressing transfer tax minimization, succession planning, and intergenerational wealth preservation. Our team routinely handles:

• Wills and revocable/living trusts
• Irrevocable trusts (GRATs, IDGTs, SLATs, QPRTs, charitable trusts)
• International estate planning, pre-immigration and expatriation strategies
• Probate and trust administration in Florida and other jurisdictions
• Planning for non-citizen spouses, foreign heirs, and dual or multiple citizenship beneficiaries

Pre-Immigration and Expatriation Tax Planning

We counsel individuals preparing to immigrate to or expatriate from the United States, ensuring that timing, structure, and asset ownership align with long-term tax efficiency.

• Pre-immigration trust structuring and basis step-up planning
• Income tax and estate tax minimization strategies
• Covered expatriate analysis and exit tax mitigation
• Coordination with immigration counsel on timing and asset positioning

Real Estate Tax Structuring

We advise domestic and foreign investors on the acquisition, ownership, and disposition of U.S. real estate, including structuring for privacy, liability protection, FIRPTA mitigation, and tax efficiency.

• Blocker corporations and hybrid structures
• Real estate joint ventures and syndications
• Planning for 1031 exchanges and opportunity zones
• FIRPTA withholding compliance and refund claims

Charitable Organizations and Philanthropic Planning

We counsel individuals, families, and nonprofit organizations in the creation, administration, and compliance of charitable structures. Our work includes planning and structuring charitable gifts and philanthropic legacies in ways that maximize impact while providing tax benefits.

• Formation and qualification of U.S. charitable organizations (501(c)(3) and related entities)
• Ongoing tax compliance and reporting obligations for nonprofits
• Structuring and administration of private foundations and donor-advised funds
• Cross-border charitable giving and international grantmaking strategies
• Charitable remainder trusts (CRTs) and charitable lead trusts (CLTs)

Our taxteam is ready to defend your brand—connect with us today.