Our attorneys have combined many years of experience in the bulge bracket representing publicly traded companies and financial institutions. However, one of our key motivations in founding our firm is to transfer those years of experience to private individuals and families. In keeping with those principles, we counsel individuals with interests in privately held enterprises, private funds and other middle-market clients. Some examples of this practice include immigration and pre-immigration tax planning as well as normalization of individual tax delinquencies and offers in compromise.
For example, it is common for US citizens or residents to open and maintain financial accounts outside of the United States. The reasons can be endless. Nevertheless, the IRS mandates anyone holding accounts with an aggregate of more than $10,000 on any single day during the calendar year to report such accounts, even if such account holder did not earn interest or any other income abroad. Failure to report offshore accounts can lead to excruciating civil penalties and sometimes even criminal charges. However, the IRS has implemented a few programs that allow taxpayers who are delinquent in their reporting to voluntarily notify the government of their accounts with lesser consequences. Our firm counsels clients with these kinds of issues, and we pride ourselves in providing quality representation across a profile of large and small clients.