The Law Offices of Jonathon R. Moore, PLLC is highly regarded for its domestic and international tax expertise. With respect to international tax issues, it advises on all aspects. These include, for example, corporate taxation, individual taxation, the rules applicable to trusts and beneficiaries, gift and estate taxes and withholding taxes. We have been extensively involved in representing clients seeking to avail themselves of the Voluntary Disclosure Programs administered by the Internal Revenue Service to bring taxpayers back into compliance with tax and reporting requirements.
We are also actively engaged in assisting financial institutions, trusts, companies and individuals comply with the numerous new requirements under the Foreign Account Tax Compliance Act (“FATCA”).
The Firm advises as to many types of so-called “in-coming” transactions. These include investments in and acquisitions of U.S. real property. For example, we advised a non-U.S. group with respect to a series of U.S. real estate investments and later the disposition of those investments. We frequently assist non-U.S. Clients in structuring investments in real property in the United States, so as to avoid potential imposition of U.S. estate taxes.
The Firm advises U.S. taxpayers on business and personal investments abroad.
A common engagement involves clients from several jurisdictions, with transactions that touch down in two or more jurisdictions. For example, we recently advised European clients with respect to acquisitions and privatizations in southeast Europe. On another occasion we advised Bermudan and U.K. principals as to the start-up of a business in Mexico.
Areas of special concentration have been the taxation of export transactions and foreign subsidiaries of U.S. groups. The latter entails the controlled foreign corporation rules found in Subpart F of the Internal Revenue Code.
The Firm often advises U.S.-based or foreign-based multinational enterprises on the structuring of international business transactions.
We engage in tax planning for clients. This work often calls for a significant degree of creativity.
The Firm sometimes obtains Internal Revenue Service rulings for clients. More frequently, clients and their investors and lenders rely upon our opinions.
In addition, we deal with compliance and tax litigation. We help clients “catch up” with their filings of tax returns and foreign bank account reports.
