Income and Estate Tax Planning: Are you fortunate enough to have so much income or such a large estate that the federal and state income or estate tax costs will be massive? We have the tools that might help you reduce those taxes.
Wills and Trusts/Asset Protection Planning: Do you want to be sure that those who you intend to receive your wealth during your life and after your death actually get what you intend--and keep it away from prying hands? That is what we do.
State Tax Residency: Do you have residences in more than one state (perhaps New Jersey and Florida) and need to be sure that you are paying taxes to the correct state. We can help you arrange your circumstances appropriately and represent you in any state tax audits or lawsuits that challenge your residency (for both income tax and estate tax).
Offshore Assets and Accounts: Do you have assets and accounts outside the US and you are a US taxpayer? Then you probably know by now that you have reporting obligations to the IRS and severe penalties for failing to file these reports. We have the experience to help you wend your way through this process. You might qualify for one of the programs that reduce or eliminate the penalties.
Captive Insurance Companies: Are you among the small and mid-size companies throughout the country that have learned of the benefits of captive insurance companies? These privately owned P&C insurance companies are designed to control risk and deliver major reductions in insurance costs. When structured appropriately these also may have major tax benefits. Our experience with captive insurance companies goes back to the early 1980s. Click here for the analysis of Notice 2016-66
Life Insurance Trustee Risk Management: Institutional ILIT trustees do not always fully appreciate the panoply of risks to which they are exposed and the best practices to manage them. Even when they think they have managed them and protected themselves they are often wrong. We can build the program that firewalls the trustee from these risks.
419 Plan IRS Audits and Tax Court Representation: Have you found yourself next on the IRS' list for their attack on 419 Plans and 412(i) Plans? Whether you are approaching audit or have already received the inevitable 90 day letter and have only the Tax Court to which to turn there are softspots and weaknesses in several of these cases that allow experienced lawyers to minimize the ultimate costs. We know where these lurk and can provide the client references to help you decide if we are right for your case.
419 Plan Civil Litigation Expert Witness: Whether you are plaintiff's counsel or defense counsel you know that these cases are complicated and dense with technical tax issues. You also know that the key to a good expert witness is one who has excellent credentials, knows the subject inside-out and can explain it in such a way that engages the jury and the judge. Contact us and we will provide you with the references from lawyers across the country--on both sides--who will tell you if David fits that bill.
Facilitating international business transactions: If you are a US-based company looking to expand markets or license product beyond the limitations of our shores or you are a foreign-based business hoping to tap into the great potential of the US marketplace, we have the experience and network to make that happen.