Tax Planning

Individual Planning
In this practice area, we assist our clients in minimizing their Florida and federal individual tax liabilities. This often involves or includes:

+ Resolving questions about how the law applies to a client’s situation
+ Planning to defer taxes, through like-kind exchanges, contributions to qualified retirement plans, installment sales and other mechanisms
+ Planning to minimize or avoid Florida sales, documentary stamp, intangibles, and other taxes
+ Maximizing the use of favorable capital gains and qualified dividend rates of tax
+ International tax planning, including use of tax treaties, foreign earned income exclusions, U.S. taxation of nonresidents, FIRPTA, foreign trust taxation, withholding taxes, residency determinations, portfolio interest obligation planning, U.S. real property interest planning, international exchange of information, foreign tax credit planning
+ Tax reporting and compliance
+ Deduction limitations

Entity Planning
In this practice area, we assist our clients in minimizing their Florida and federal tax liabilities that relate to entities. This often involves or includes:

+ Determining the best or most appropriate entity to use
+ Entity formation, including corporations, LLC’s, partnerships, business trusts, and land trusts
+ Entity agreements, including operating agreements and partnership agreements structured to achieve tax, asset protection, and business objectives and benefits
+ Stock option plans and agreements, phantom stock arrangements,

Business Structuring
In this practice area, we assist our clients with structuring their businesses and transactions in a tax efficient manner. This often involves or includes:

+ Planning for business formation, redemption, and liquidation transactions
+ Structuring of purchase and sales of businesses and assets
+ Structuring and compliance with tax incentives and provisions relating to mergers and reorganizations
+ Advantageous use of agency and contractor agreements and royalty and licensing agreements
+ Use of compensation and other payment arrangements to reduce entity taxation

Retirement Planning
In this practice area, we assist our clients with their retirement planning issues, including:

+ Pensions, traditional IRAs, Roth IRAs
+ Nonqualified retirement planning
+ Insurance as a retirement plan
+ Contribution and distribution planning

International Business
In this area, we assist our clients with relevant international tax issues, including:

+ Planning for CFCs, PFICs, DISCs
+ Check-the-box planning and elections
+ Importer and exporter planning
+ International reorganizations, including Section 367 and inversion rules
+ Royalties and intangibles planning
+ Tax reporting and compliance
+ FATCA
+ Special provisions relating and air and shipping business
+ Section 482 and other limits on related party transactions
+ Earnings stripping
+ Foreign tax credit planning

Preimmigration And Expatriation
In this area of practice, we assist taxpayers who plan to come to or leave the U.S. This typically involves the:

+ Review and structuring of holdings, businesses, assets, and circumstances for persons contemplating immigrating into the U.S.
+ Review and planning of for persons contemplating expatriating from the U.S.

Tax Planning

tax, estate planning, probate, trust & guardianship law and litigation, and related commercial matters