Taxation Experience You Can Trust…
US companies or individuals with income or operations abroad, or foreign companies or individuals with income or operations in the US, are subject to a number of international tax issues. Klug Law Office PLLC provides comprehensive tax services for our business and individual international tax clients. Our firm provides advice with respect to both inbound and outbound transactions, investments, and operations in an increasing global economy.
As more companies explore opportunities to expand outside their traditional borders, international tax law becomes increasingly more important. A company planning a cross-border transaction, operation, or investment must deal with a number of complex US tax rules. The structure chosen will have immediate
and long-term tax consequences. Advising clients on cross-border transactions involving the United States requires both an understanding of US tax law and how that transaction will interact with the laws of other countries that are relevant to the transaction. Our firm works with companies to structure cross-border transactions and provide efficient and practical advice related to global expansion.
Outbound Tax Planning
Klug Law Office PLLC provides tax counsel to US based clients that have or are expanding abroad. Our services include structuring/restructuring; mergers, acquisitions, and disposition; joint ventures; anti-deferral provisions; foreign tax credits; repatriation planning; tax treaties, tax compliance; and avoiding traps for the unwary. Our firm works closely with US based and foreign advisers to ensure a comprehensive plan and structure as part of our outbound tax
Inbound Tax Planning
US tax planning is essential for any foreign business expanding into the US. Klug Law Office PLLC advises clients from around the world on their US based operations. Our services include structuring/restructuring; mergers, acquisitions, and dispositions; joint ventures; determining whether an activity constitutes a US trade or business or permanent establishment; repatriation planning; treaty planning; investment in US real estate; tax compliance; and avoiding traps for the unwary. Our firm works closely with US based and foreign advisers to ensure a comprehensive
plan and structure as part of our inbound tax planning services.
The US requires its citizens and residents to report and pay tax on their worldwide income. US citizens who reside outside the US are required to file annual US tax returns (if their income exceeds the filing thresholds), and may have to file a Report of Foreign Bank and Financial Accounts (FBAR) or Foreign Account Tax Compliance Act (FATCA) statements. Our firm represents clients who have not filed US tax returns or FBARs for many years and works with them to find solutions to bring them into compliance with their filing obligations.
At the Klug Law Office PLLC, we both advise and prepare the tax returns for US citizens living abroad or US based clients with foreign assets. We have extensive experience in this area and are well equipped to handle the more complicated returns where there are treaty positions, foreign companies, passive foreign investment companies, controlled foreign corporations, subpart F inclusions, non-US retirement plans, and any other complicated issue that may arise. It is our experience that a US citizen living abroad or a US based client with foreign assets and income, needs to be working with a tax professional that
understands the complicated tax rules and international informational forms that must be filed. The penalties associated with failure to properly file the international informational forms are too severe to leave to a tax preparer with little or no experience in the area.
Klug Law Office PLLC represents high net worth individuals, families, family offices, and closely held businesses in their cross-border activities and succession planning. Our services for foreign clients include: US tax planning for non-US individuals planning to come to the United States; determining when
a non-US individual becomes a US resident for income and estate and gift tax purposes; pre-immigration tax planning; and tax planning for investors who will become permanent residents through an investor visa program.
Our services for US clients include: US tax planning for US individuals who live abroad or have significant assets abroad; US tax planning for US citizens and “green card” holders who are long-term residents planning to expatriate or relinquish their “green card”; advising individuals with respect to US tax reporting and informational return compliance; advising individuals and families on the use of trusts for estate planning; and tax treaty planning.
Offshore Account Compliance
US persons are required to file various international informational returns in connection with their foreign investments and activities. The Report of Foreign Bank and Financial Accounts (FBAR) and IRS Form 8938 (individual FATCA compliance) are important informational filings for US persons with foreign
accounts and assets. The failure to file the FBAR or Form 8938 carries large civil penalties and if the non-filing is willful, criminal penalties. Klug Law Office PLLC advises clients on their FBAR and Form 8938 filing requirements, prepares FBARs and Form 8938, and advises clients on how to come into compliance if the FBAR and/or Form 8938 filings have not been completed for prior years.
Klug Law Office PLLC represents clients through the IRS Offshore Voluntary Disclosure Program (OVDP) and Streamlined Domestic/Foreign Offshore Procedures. These programs offer options to US persons to bring their foreign accounts reporting into US tax compliance, both in cases of willful noncompliance (OVDP) or nonwillful noncompliance (Streamlined Domestic/Foreign Offshore Procedures).
Tax treaties include income tax treaties and estate and gift tax treaties. Tax treaties are bilateral agreements between countries. One purpose of an income tax treaty is to mitigate double taxation. In cross-border matters, it is important to determine whether a treaty is applicable and understanding the
treaty’s benefits is key to tax planning.
Our services for income tax treaties include: whether an individual or resident is a resident under the treaty; treaty tiebreaker provisions; application of the limitation on benefits provision; eligibility for favorable tax rates; taxation of income from employment; whether a permanent establishment exists; attribution of profits; associated enterprises; and relief of double taxation and source of income provisions.
Our services for estate and gift treaties include: residence determination; situs of assets; tax credits; and other benefits or exemptions under the applicable treaty.