After working in Beverly Hills, CA and Toronto, ON in the tax department of national firms, Steve moved to Toronto in 1993 and started Crossborder Tax Services in 1997. You should receive an email confirming your registration shortly at the email address provided in your registration form. Tax Strategies for Israelis Moving to the US, Pt 2 - Bloomberg Tax Utilization is the third prong of our holistic tax planning approach. Cross-Border Tax Planning Lawyer | International Tax Planning Attorney | Lance Cross-Border Law and Tax. Reduced rates will . but once it is over, you can emerge and focus on living your life. I have been send from left to right and no one could help me until I found Mark. Associate Lawyer in Cross Border Tax and Estate Planning Structuring nonresident investment in cross-border business operations in the US requires the same coordinated planning under both the US tax system and the tax system of the investors home country, as well as tax treaty planning in some cases. Possible Israeli-U.S. Cross Border Business Issues . In this regard, we regularly defend nonresidents who receive a Form 4600 inquiry letter from the California Franchise Tax Board (FTB) questioning their residency status or asking them to file a California income tax return. They do so by asking you to complete their questionnaire (not recommended) to learn enough about you to determine whether they think you should have filed a nonresident tax return, a part-year resident return or a resident income tax return. Practice GPA 3.98. Your speaker request has been sent by email to our team who will be in touch within two business days to help coordinate the logistics for your event. Canada/U.S. Initial consultations Cross-Border Tax Attorneys: International Tax matters require Cross-Border Tax Attorneys who specialize in representing clients worldwide with offshore disclosure, compliance, planning, & penalty mitigation. For months I searched unsuccessfully for someone with cross-border knowledge to help me navigate the financial and tax impacts of relocating from the United States to Portugal. Hodgson Russ regularly advises businesses and individuals around the world in all areas of U.S. law, including: Our attorneys work together to negotiate successful agreements for a broad spectrum of business relationships, including commercial agents, distributorships, employment, franchising, joint ventures, leasing, licensing, marketing, noncompetition, partnerships, sales, shareholder relations, strategic alliances, and other corporate and commercial matters. We encourage prospective US citizens having cross-border business and investment interests abroad to learn about and plan for the myriad worldwide tax consequences of US citizenship before taking the oath. 2020 Pennsylvania Avenue NW #530, With all the issues that arise for US citizens living in Canada, the idea of renouncing US citizenship is a common one. BRENT LANCE, LL.M. A special expatriation tax regime exists to deter wealthy U.S. citizens from relinquishing their citizenship in order to avoid future U.S. taxes. Sean M. Goldingis one of less than 350 Attorneys (out of more than 200,000 practicing California Attorneys) to earn the Certified Tax Law Specialist credential. He has been licensed in the Province of Ontario since 1992, and the State of New York since 1993. given his knowledge base, collaborative nature, and dedication to helping clients find solutions that work best for their case. With professional accounting designations in both Canada and the US, coupled with admittance to the bar in both countries, the firms founder, Mark Feigenbaum, and his team are uniquely positioned to consult on tax and financial strategies and represent the legal interests of clients on both sides of the border. Any other international/multilateral arrangements that may be applicable. Indeed, residence-based taxation may result from a seasonal visit that would not expose a non-nomadic visitor to such taxation. Tax treaties are very rudimentary and the wording that is used therein can be ambiguous. In addition, the depth and breadth of the firms knowledge of both Canadian and US tax laws, uniquely qualifies them to advise clients with cross-border interests including property holdings, employment arrangements, and immigration requirements. Email: george@babits.ca The keys to such opportunity are making the change tax effective and effectively managing the date when the change becomes tax effective. For departures not expected to be permanent (e.g., other state or overseas work assignments), a change of tax residence is possible, even if a change of tax domicile is not. 20-years experience as a practicing attorney, Extensive litigation, high-stakes audit and trial experience, Board Certified Tax Law Specialist credential. The Canadian offices are strategically located in Montreal, Toronto, Calgary and Vancouver to service all Canadians who enjoy a cross-border lifestyle. The one-hour webinar is open to all professionals and is being presented at no charge. What Should You Do to Protect Yourself and Your Nonresident Spouse? . We can likewise assist nonresident investors in US businesses with US information reporting obligations and planning for sale of the business, taking it public or other possible exit scenarios. Learn More. This button displays the currently selected search type. We also have decades of experience working with dual residents who are Treaty Nonresidents, interpreting tax treaties and determining whether and the extent to which you qualify for treaty protection from US income tax. We also offer similar expatriation tax planning for dual citizens considering abandonment of US citizenship (e.g., to avoid future US tax filings or tax on non-US income), as well as US citizens wishing to expatriate and acquire citizenship overseas in a lower tax environment. California Domicile Change: On What Day Does it Occur? Watch our introductory video and see how Feigenbaum Consulting can help you. Marks knowledge and network was outstanding, he was always open for discussions and helped me guide through the whole process which took over a year. Our tax-efficient cross-border vacation home ownership structures allow you to avoid making such gratuitous disclosures, as well as other potentially disadvantageous tax effects of individual home ownership, which include high California individual income tax rates and imposition of nonresident withholding taxes on sale. If the FTB is dissatisfied with your response to their residence inquiry and tax return request, and they continue to demand additional information and documentation from you, that may be the beginning of a residence tax audit. Many of our clients are based in civil-law jurisdictions, in particular, France. Disclaimer | Privacy Policy | Website designed and managed by Umbrella Financial Marketing. The provisions of the tax treaty between both countries; 4. The tax rules of the residence country; 3. We are especially dedicated to assisting seasonal visitors to California to avoid paying California income tax. Those transfer taxes are in addition to US income and capital gains taxes! Even a dollar of California source gross rental income requires the filing of a California income tax return each year that rent is received (even if no tax is due), with attendant annual disclosures of your sensitive personal information to the Franchise Tax Board. Feigenbaum Consulting clients have peace of mind knowing that their matters are being handled by a cutting-edge team with years of widespread experience. Learn More, International pension planning is one of the cross-border areas our firm specializes in. Lance Cross-Border Law and Tax ("Lance Cross-Border") is the premier cross-border tax law firm in California. Golding & Golding specializes exclusively in international tax, and specifically IRS offshore disclosure. Master 2 Professionnel Business & Tax law. document.getElementById( "ak_js_1" ).setAttribute( "value", ( new Date() ).getTime() ); Canada Unlike virtually all other developed countries, the US taxes its citizens on their worldwide income (with a few exceptions), without regard for their place of residence. Golding & Golding Testimonials from prior clients. Feigenbaum Consulting provides skilled legal representation and expert witness services in the following areas: As the saying goes, knowledge is power. In this second part of the two-part series, Melvin Warshaw and David Lesperance look at the interaction between tax and immigration law consideration and possible strategies for Israeli entrepreneurs considering a possible relocation from Israel to the United States. If you already own a California vacation home in your individuals name(s), we can help you with a quiet restructuring, which will avoid the need to file a tax return, the imposition of withholding taxes or the disclosure of other sensitive personal financial information. Notwithstanding your possible status as a Treaty Nonresident, however, the IRS and US Treasury still take the position that dual residents still have US information reporting obligations. Cross Border Trusts | Barrett Tax Law The Parliament signed amendments to the excise duty law that include the following provisions: Starting from 2023, there will be a gradual phasing out of fossil fuel benefits and subsidies applied to gasoil, coal, coke, lignite, diesel, liquefied petroleum gas in cylinders, and excise tax rates will be consistently increased. As discussed above, application of the expatriation tax regime on the relinquishment of your green card can have painful tax repercussions for those who do not plan to avoid it. For all of our individual clients, we offer US estate tax, gift tax and other US transfer tax planning, in addition to cross-border income tax planning. Read More, Licensed Paralegal The dual discipline practice is particularly helpful in areas such as family law, estate litigation, and sports & entertainment law. 2007 - 2011. We also defend our clients who become embroiled in residency tax audits with the FTB. We can assist you with support, outlining which forms you need to file for a particular cross-border transaction. Corporate - Cross Border Tax Law He exceeded my expectations. Print. Cross-border alimony and migration I have met mark through a friend of mine who was in a similar situation as me. To be effective, some elements of your pre-residence tax plan must be implemented prior to arrival (i.e., prior to the first day of U.S. residence). Cegedim SA Represented by Hodgson Russ in Its Acquisition of Dendrite International, Inc. That is why utilization is an integral component of our approach to tax planning. He has the knowledge, the ability to communicate complex information in clear terms, and provides extremely useful advice. Should you have any questions, please contact our Marketing Manager, Elena Trigiani, at the email address below. The best way to get guidance on your specific legal issue is to contact a lawyer. Polaris Tax Counsel is a cross-border tax law firm. Email: jfeinberg@altrolaw.com Solicitor, Senior Courts of England & Wales 2000, LL.M. Feigenbaum Consulting is a full-service solution for both advocacy and consultation on financial and legal matters. 2011 - 2012. Nonresident tax planning for international cross-border investments is a multi-dimensional process involving coordinating US income tax law (as well as state income tax provisions) with the tax law of the investors home country (and possibly that of third countries where holding companies or trusts may be located). Connect with Us Lance Cross-Border Law and Tax ("Lance Cross-Border") is the premier cross-border tax law firm in California. Your subscription to our newsletter has been received. Many US citizens and green card holders wish to cease paying US income taxes on their investment and business income, but stop short at the idea of giving up their US citizenship or green card to accomplish that. Perhaps these individuals came to Canada as young children [], With 35 years of experience, the team at Altro LLP is consistently delivering a very high level of legal expertise, knowledge, service and professionalism to our clients, Managing Partner, Florida Attorney, Read More, Partner, Ontario, New Jersey, & New York Attorney Universit Paris Ouest Nanterre La Dfense Double bachelor degree in French law & common law Business law High honors. We also encourage our attorneys to continually improve their knowledge and grow professionally with the publication of articles written on the areas of the law practiced at our firm. Cross Border Tax and Transactions Michael Cirone | Canada & U.S. Cross-border Lawyer - TaxChambers "We're looking at possibilities of legislative action, but this is not a very realistic way to go," said Henrik Paulander, head of sector administrative cooperation . Hi, my name is David Kerzner. Associate Lawyer in Cross Border Tax and Estate Planning Montreal, QC, Canada | Posted on 06/19/2023 APPLY NOW Share this job Position: Associate Lawyer in Cross Border Tax and Estate Planning Job Type: Full-Time, Permanent Location: Downtown Montreal, Quebec Firm: Levy Salis LLP Anticipated Start Date: Immediate Overview: If you already own a California rental property in your individuals name(s), we can help you with a quiet restructuring, which will avoid the need to file a tax return, the imposition of withholding taxes or the disclosure of other sensitive personal financial information. Founded in 1988, Altro LLP provides superior cross-border and domestic tax, estate planning, and real estate services to high net-worth individuals and families across Canada and the United States. 2022, 22, 2, 630-635 14 janvier 2022 The Wiedemann-Franz law states that the charge conductance and the electronic contribution to the heat conductance are proportional. This absence often results in significant tax costs for the beneficiaries. We can optimize your tax position with respect to your international pension distributions, and also take care of the full implementation of our planning. If you do not actively plan how to deal with your tax burden, you risk losing income or gains you have earned. The Lexpert Guide to the Leading US/Canada Cross-Border Corporate Lawyers in Canada. Crossborder Tax Services provides US and Canadian tax consulting and compliance services to individuals, corporations and other tax professionals in Canada and the U.S. A Note for Canadians with US gambling winnings. Feigenbaum Consulting offers full-service legal, accounting, and tax solutions in Canada and the United States. Email: matthew@silverimmigration.com The team at Feigenbaum Consulting provides effective, knowledgeable guidance and consulting services for a variety of Canadian and cross-border legal and financial matters. Andersen in Canada also focuses on U.S. and Canadian cross-border tax matters. This network and our own extensive relationships help provide Hodgson Russ clients with effective assistance in selecting competent counsel in all of the significant commercial countries in the world. Through Sales Representatives or Distributors. Pre-residence California tax planning is extremely important for individuals moving to California. *Please beware of copycat tax and law firms misleading the public about their credentials and experience. For investments in US real estate, we incorporate FIRPTA withholding tax avoidance and recovery, structuring financing, as well as planning to reduce US taxes on rental income into the analysis. Cross-Border Tax Toronto Tax Lawyer Representing Clients in Cross-Border Tax Matters Feigenbaum Consulting has a strong focus on the legal and financial complexities that arise when money crosses the border. Individuals - Cross Border Tax Law We are able to bring in this top talent as adjuncts and have non-U.S. tax experts teach alongside U.S. tax lawyers to show the real-world dynamics of developing a structure that satisfies the business and legal demands of multiple jurisdictions. They regard personalized service as the hallmark of their approach and ensure their clients remain well-informed about their matter by prioritizing accessibility. Each choice has a different outcome, some better than others. Contact the firm online or by telephone at (905) 695-1269 or toll-free at (877) 275-4792 to book a consultation. 2023 Feigenbaum Consulting. I then further engaged him to provide tax planning advice for my alimony payments, my retirement funds, and my subsequent migration to the Netherlands. PERSONAL TAX SERVICES USA TAX RETURNS US federal and state tax returns for US citizens and non-residents FOREIGN BANK ACCOUNT REPORT FBAR IRS VOLUNTARY DISCLOSURE IRS Streamlined Filing Procedures and Offshore Voluntary Disclosure Program US REAL ESTATE For those who didnt have the advice they needed when becoming US residents or citizens, we have experience getting the IRS to waive or reduce delinquent filing penalties if you qualify to enter an IRS tax compliance program. Led by Managing Partner David A. Altro, Florida Attorney, Canadian Legal Advisor, Foreign Legal Counsel and Quebec Notary, author of the industry leading books OWNING US PROPERTY THE CANADIAN WAY, 3rd Edition, and also AMERICANS LIVING IN CANADA: SMILE, THE IRS IS WATCHING YOU, our team is ideally positioned to serve clients needs with offices in Canadas largest metropolitan cities of Montreal, Toronto, Calgary and Vancouver and throughout the US Sunbelt states of Florida, Arizona, and California. But in many cross-border transactions, your income is subject to complex multi-national tax rules and principles. Unlike other areas of Tax, when it comes to International Tax, Cross-Border, and Offshore/Overseas Tax Compliance your attorney should be a, We are the go-to firm for other Attorneys, CPAs, Enrolled Agents, Accountants, and Financial Professionals across the globe. Our focus is on California, Federal and international cross-border tax issues that affect individuals and businesses having cross-border interests. We also advise green card holders who failed to formally relinquish those visas concerning the implications of late abandonment (the IRS position is that you are still a US income tax resident)! Building wealth and protecting assets require a clear plan that evaluates your current financial situation and predicts what your future finances might look like, based on the financial decisions you make. Such attributed income will give rise to a California income tax return filing obligation for the nonresident spouse (and also a U.S. income tax return filing obligation for my Canadian and other foreign nonresident clients, as well). But realizing tax benefits in one country is not enough in a cross-border setting. Partner. With tax attorneys resident in the United States, France, Germany and the United Kingdom, the firm is capable of providing advice in various jurisdictions on a multitude of issues. We have some great ideas we would like to share with you. Email: schan@altrolaw.com Under that definition, it is possible to become a long-term resident by spending as few as 6 years and two days as a lawful permanent resident (ask us how). Email: daltro@altrolaw.com The FTB tracks and taxes to nonresident individual owners of flow-thru entities the business profits of those entities that are allocated or apportioned to or sourced in California. His clients have included law and accounting firms in Canada and the U.S., Canadian public companies, family-owned companies with international operations or ownership, and individuals. We also counsel our US resident clients concerning foreign bank accounts reports (FBARs) and other foreign asset and foreign information reporting obligations, including those whose filings are delinquent and who need help coming back into compliance, with minimal or no penalties. We have decades of experience assisting clients to avoid or minimize US transfer taxes in structuring their US investments and in planning for asset transfers as part of our cross-border estate planning practice. We have helped many clients throughout the world,and the surrounding areas with all aspects of IRS Offshore/Voluntary Disclosure. Prior to forming Feigenbaum Consulting, Mark worked in the cross-border tax department of an international Big 4 firm and held accounting management positions in a range of sectors in both Canada and the US. Read More, Licensed Paralegal Did we respond to your emails and telephone calls promptly? The webinar titled Immigration, Cross Border Tax and Financial Planning Strategies is targetted for professionals immigrating to the US with the H1-B visa and Human Resources professionals who work with relocated employees. GET YOUR FREE TAX EVALUATION About The firm offers a range of services in this highly niche area including proactive advice, compliance assurance, and tax planning strategies. This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply. We are pleased to welcome Stephania Fahmi (LL.L.) The firms founder, Mark Feigenbaum, is an astute lawyer, who holds law degrees from both Canada and the US. Lawyer in Boydton, VA Expand search. This is especially true when matters of law and finance intersect. Our firm is specialized in international tax solutions for Inherited IRAs with a very impressive track record of results. For example, inter-vivos trusts in the US often refer to the "grantor", which is a term not ordinarily used in domestic Canadian trusts. Alan Kenigsberg | Cross Border Tax Lawyer in Toronto Home Team Alan Kenigsberg Partner, Tax Key Contact: International Trade and Investment Contact Information akenigsberg@osler.com tel: 416.862.6659 Office Toronto Download vCard Download Profile Biography Bar Admission Ontario, 2001 Education Osgoode Hall Law School, LL.B. Our attorneys have worked with, *Please beware of copycat tax and law firms. I have been looking all over the internet trying to find a tax lawyer that understands both the Dutch and the US tax system. Individuals who are planning to become US residents need a pre-residence tax plan. Email: swu@altrolaw.com Submitting a contact form, sending a text message, making a phone call, or leaving a voicemail does not create an attorney-client relationship. We have worked on several mutual clients that have resulted in positive outcomes for our clients. International Tax Partner, National Practice, Marcum LLP. It is a common in my practice to have one spouse become vulnerable to being treated as a California income tax resident, while the other does not. your u.s. & Canada cross border tax experts. and Eric Miller (J.D.) I have been looking all over the internet trying to find a tax lawyer that understands both the Dutch and the US tax system. Sadly, there are no general or international rules to deal with the scenario of double and over taxation. Feigenbaum Consulting provides consultations and strategic tax advice to clients on both sides of the Canada/US border. At ALTRO LLP we are experts in our field and are often interviewed on television and the radio or quoted in newspapers, journals and magazines. Cross-Border Tax Law Services | Kerzner Law Representative clients include private and public corporations, funds (investment & pension), owner-entrepreneurs, professionals and their business entities, individuals, trusts, and estates. Learn More, Cross-border transactions are often subject to very strict reporting and filing requirements. READ MORE Dan Palmer J.D. Naturally, you will have to pay your fair share of taxes. We will respond to all relevant inquiries without any obligation. EU Tax Rules for Cross-Border Workers Unlikely, Official Says With six offices in the United States and Canada, including in the major financial and business markets of New York and Toronto, and much of our infrastructure in lower-cost jurisdictions, we are able to offer our clients the full range of excellent-quality legal services of some of North Americas top economic markets without the disproportionate expense of other large U.S. firms. Understand how to navigate complex international tax concepts under Canadian and U.S. law with this resource written specifically for business entrepreneurs, COOs, CTOs and CEOs and MBAs. A Lifetime of Experience With Cases Like Yours! Cross-Border Tax Attorneys - International Tax Planning & Compliance (Golding & Golding) If you do not receive this email (inbox or junk mail) or have questions after receiving the confirmation email, please contact our Marketing Manager, Elena Trigiani, at the email address below. If you live a modern-day nomadic lifestyle and spend part of each year in California, we have considerable experience helping people with lifestyles like yours to minimize their exposure to California residence-based taxation. We also integrate US withholding tax planning for cross-border cash flows and international double taxation avoidance into our advice. Cross Border Tax In the April 2022 federal budget, the Canadian government proposed significant changes to the Canadian international tax rules (specifically the foreign accrual property income or FAPI rules). To schedule a consultation with Dr. Kerzner please call or submit an inquiry below. Over the years, Mark has become our go-to colleague when advising U.S. and European clients when dealing with cross-border tax matters (e.g., pre-immigration planning, business restructurings, asset sales, wealth and succession planning, expatriation, etc.) Our team of US and Canadian-licensed attorneys have the unique ability to create tax and estate plans and then implement legal structures in accordance with the laws of relevant jurisdictions on both sides of the border. Founded in 1988, Altro LLP provides superior cross-border and domestic tax, estate planning, and real estate services to high net-worth individuals and families across Canada and the United States. Copyright 2021 / Privacy Policy / Sitemap. In our experience, the most effective expatriation tax planning occurs when a cross-border tax planning attorney is consulted long before the date you wish to relinquish your citizenship. We also represent clients to appeal unjustified IRS tax assessments resulting from an audit. Dave Roberts is a lawyer who carries on an international tax practice, based in California, focusing on Canada U.S. tax planning, issues, and strategies. If you are a dual resident, we can guide you through these, as well as other special tax filing requirements and related cross-border tax planning. The Portuguese tax system applies a flat 10% tax rate under the NHR regime, but this regime does not encompass capital gains (which are taxable at 28%). Our network partners can file these forms for you when desired. Eyeing Opportunities in Mexico, Clark Hill Adds Cross-Border Tax Lawyer The key to remaining a California nonresident while living part-time in California is tax planning that involves three distinct disciplines: (1) cross-border lifestyle planning that allows you to defend your non-residency status, if questioned (our cross-border tax planning lawyer acquaints our clients with over 40 cross-border lifestyle factors that should be considered in such planning); (2) understanding how the FTB collects information about you, staying below the radar and avoiding the gratuitous disclosure of sensitive personal and financial information to the FTB; and (3) if needed, re-structuring the manner in which certain income is earned, assets are held and expenses are incurred to limit the amount of tax California can assess, whether your nonresident status is upheld, or you are determined to have become a California tax resident.

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