Asset Protection

I undertake sophisticated tax, estate and asset protection planning for high net worth individuals. My planning advice is tempered and informed by my extensive experience in tax and related litigation. Put simply, I have a much better understanding of what actually works when put to the test in an IRS audit or in court. Here are examples of the services I provide:

Sophisticated Estate and Asset Protection Planning

    * Family limited liability companies

    * Grantor trusts

    * Irrevocable life insurance trusts

    * Grantor retained annuity trusts (GRATs)

    * Charitable remainder and lead trusts

Foreign Trusts and International Tax Planning

    * Discretionary foreign trusts

    * Advice on tax reporting for foreign trusts, Forms 3520, 3520-A

    * Advice on reporting forms related to the ownership of foreign accounts and financial assets, FinCEN Form 114 (FBAR) and Form 8938 (FUBAR)

    * Advice on offshore reporting requirements related to foreign operations of U.S. owners, Forms 5471, 8865 and 8858

   * U.S. tax and estate planning for expatriates and non-residents

   * U.S. tax and estate planning for expatriation and relinquishment of green card

Domestic Estate Planning

    * Living Trusts

    * Wills

    * Advance Health Care Directives


Decedent Estate Administration

    * Living trust administration by successor trustees

    * Tax issues on trust distribution

    * Notification of trust beneficiaries and certification of trusts

    * California Probate Code §850 Heggstad Petitions

    * California Probate

Entity Formation, Reorganization and Liquidation

    * Limited liability companies

    * Corporations

    * Partnerships

    * Non-profit corporations

Retirement Investment Planning

    * Retirement account limited liability companies

    * Roth conversions

    * Avoidance of prohibited transactions

    * Unrelated business income tax

Real Estate Tax Planning

    * Real estate purchase, leasing and disposition

    * Deferred Section 1031 exchanges

Investment Transactions

    * Installment sales

    * Stock options, short sales, straddles and collars

    * Planning for original issue discount and imputed interest

    * International investment in precious metals