Practice

Tax Planning & Disputes Tax Planning & Disputes
Corporate and Business Corporate and Business
Estates & Trusts Planning and Assets Protection Estates & Trusts Planning and
Asset Protection
Real Estate Real Estate
Immigration Immigration

Practice Areas

Tax Planning & Disputes:

Inbound: We advise non-US clients in connection with negotiating, structuring, operating and liquidating their United States investments and business interests in a tax efficient manner and all related foreign investment and tax reporting and compliance. We also advise non-US individuals wishing to reside or spend considerable amounts of time in the US on the global tax consequences of their US presence and what can be done to minimize their global tax burden. The most effective tax planning is often done well before a foreign person invests, conducts business or moves or spends considerable time in the US. As a result, we integrate and emphasize trust, estate and pre-immigration planning in our practice.

Outbound: Advise United States clients as to the US tax implications associated with their offshore investments and business interests, including financing and investment transactions, joint ventures, licensing, distribution, representation, sales, purchase and service agreements.

Tax Disputes: We can provide assistance at all stages of the tax or compliance dispute from audit, where information management and scope is critical, through appeals and litigation, where the relative merits of the client's case must be presented effectively. We can also assist clients with virtually all aspects of international tax compliance, with particular emphasis on voluntary compliance cases involving US citizens or residents with non-compliant offshore accounts and unreported or underreported income.

Corporate and Business:

We advise international and US individuals and corporate clients in the structuring and maintenance of various types of business entities, financing and capital raising transactions, corporate planning, negotiation and creation of commercial, investment, joint-venture, distribution, and representation agreements, partnership, operating and shareholder agreements, and the purchase or sale of business and investment assets.

Estates & Trusts Planning and Asset Protection:

Effective estate planning requires more than the preparation of wills and trusts. Estate and gift tax planning should also be a central component of every high net worth family's succession plan. We advise clients on how to minimize estate and gift taxes, while adequately addressing the current and expected needs of multiple generations of family members. We also advise clients on how to structure and manage personal and investment assets, as well as closely-held business interests, so as to minimize exposure to certain business risks and potential creditors.

Real Estate:

Successful real estate investing requires proper tax planning before acquisition, during the ownership or operating phase and upon sale or disposition. We work closely with experienced real estate counsel representing both buyers and sellers in commercial and residential real estate projects, closings, financing, and restructuring of real estate and mortgage assets.

Immigration:

Many tax problems that international clients experience result from the failure to properly coordinate their US tax and immigration plan in advance. We work closely with experienced US immigration counsel to ensure our international clients who wish to enter the US on either a temporary or permanent basis meet their objectives in the most tax-efficient manner. We also counsel clients with respect to expatriation and post-immigration planning.

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1401 Brickell Avenue
Suite 500
Miami, FL 33131
Tel: 305.379.4400
Fax: 305.379.4802
emagno@magnolaw.com

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