U.S. Individual Tax Advice
Stuart advises individuals on U.S. tax matters including all aspects of international tax planning for U.S. citizens living abroad and pre-immigration planning for persons planning on moving to the United States including obtaining a step up to current fair market value of pre-immigration assets (including main residences). Advice also includes the maximization of foreign tax credits for U.S. persons as well as structuring U.S. affairs of non U.S. citizens to minimize current U.S. taxable income.
U.S. Corporate Tax Advice
Stuart has many years of experience advising banks, multinational companies and closely held businesses that have U.S. tax issues. This advice includes taking advantage of the U.S. treaty network, deferral opportunities permitted under the Internal Revenue Code, and structures involving hybrid entities and instruments that take advantage of mismatches among various countries’ income tax laws.
Audit and Litigation Services
The Internal Revenue Service has committed to stepping up audits of U.S. citizens and other U.S. taxpayers living abroad. Stuart routinely represents clients with audits and, on rare occasions when resolution cannot be achieved with the Examination or Appeals Offices of the Internal Revenue Service, he has successfully challenged IRS positions in court. Recently, Stuart defeated the IRS in a Federal Court of Appeals on whether certain French taxes were eligible for a foreign tax credit, resulting in the IRS having to refund over one hundred million dollars to hundred to US citizens living in France.
Other Legal Services
Clients’ affairs do not neatly fall within defined legal sectors. A client investing in U.S. real estate not only requires tax advice but also may need to form one or more corporations, have loan agreements put in place, and register the purchase in a particular state. Stuart can form and maintain such entities, put in place such agreements and, where needed, can call on a wide network of colleagues in the U.S. and abroad to ensure that all of a client’s legal needs are met.