Domestic and International Taxation, Estate Planning, Probate, Government Filing Compliance, and Asset and Creditor Protection

Domestic and International Taxation, Estate Planning, Probate, Government Filing Compliance, and Asset and Creditor Protection

The Domestic and International Taxation, Estate Planning, Government Filing Compliance, Asset and Creditor Protection, and Probate Group within our firm consists of licensed lawyers, Certified Public Accountants and former government employees with a broad range of practical, technical and business experience.

Members of this group have extensive experience in sophisticated tax-driven corporate, real estate and varying business transactions.

Generally stated, the firm's international legal services include, with the assistance of domestic and foreign tax counsel, supervising the formation and day-to-day operations of domestic and foreign companies; planning and coordinating investments into and out of the United States by nonresident and resident alien individuals, individual citizens and various types of business entities into real estate, closely-held businesses and other types of private and public businesses; structuring international joint ventures; coordinating and arranging domestic and international financing; and negotiating and drafting all types of tax-driven agreements and operative documents.

The firm handles all aspects of international and domestic income, gift and estate, state and local, and compliance tax planning with individuals and business clients, including cash flow, budget planning and executive business decisions. Also, through Fieldstone, Lester, Shear & Denberg, LLP, we offer a Corporate Maintenance and Compliance Program whereby the firm also serves as professional registered agents offering fiduciary services with the highest level of personal care and attention, including allowing entities to use our offices and services for their day-to-day business and legal needs, including corporate maintenance, updating of annual reports and board meetings.

Specifically, in this regard, the firm's domestic and international legal and compliances services include, among other things:

Providing legal advice by, amongst and between our lawyers, clients, 3rd party affiliates (e.g., bankers and realtors), internal company counsel, and foreign tax counsel for multinational individuals and companies, including, supervising the formation of domestic and foreign companies and assisting in the opening of ancillary bank accounts with strategic bank alliance partners;
Planning and coordinating investments in domestic and foreign real estate and other types of business ventures. This includes representing clients in the utilization of Section 1031 tax deferred exchange transactions, the Foreign International Real Property Tax Act (FIRPTA) withholding transactions and related planning opportunities, and contesting real estate tax assessments for commercial and residential properties;
Structuring international joint ventures and franchises while focusing on placement of strategic operations in multiple jurisdictions;
Coordinating and arranging domestic and international financing with strategic lending parties;
Negotiating and effectuating agreements in all types of domestic and international transactions and on-going day-to-day projects and business issues, such as employment agreements, and liquidation and dissolution of business entities.
Structuring implications of international, federal, state and local transactions and related corporate, partnership and individual taxation matters for all types of businesses, including, among others, mergers and acquisitions, executive and employee compensation, taxable and tax-exempt financing arrangements, and structured financing. This includes planning and drafting deferred compensation agreements, stock options, stock bonus plans, and planning with controlled foreign corporations (subpart- F income), passive foreign investment companies, and 367 “toll charges.”
Representing domestic and international clients in tax litigation and controversy work before international, federal, state and local taxing authorities, including the seeking of private letter rulings from the Internal Revenue Service.
Opining upon the special tax rules applicable to varying types of entity taxation, financial instruments and interaction with bilateral income and commerce treaties by, amongst and between the United States and other jurisdictions throughout the world, including the application and negotiations of Bilateral Treaties and Information Exchange Agreements;
Advising on individual and business entity tax planning, as related to tax return positions and preparation. This includes compliance filings for domestic and offshore individuals, public corporations, closely held businesses, partnerships, limited liability companies, venture funds, trusts, charitable and private foundations, and tax-exempt organizations.
Structuring tax planning during the initial, on-going and winding-up of multiple multi-national business areas, including, among others, real estate developments, restaurant chains, pharmaceutical companies, technology and other global business sectors;
Advising on pre-immigration (e.g., non-resident alien) income, gift and estate tax planning, and business succession planning amongst family members and business partners;
Maintaining family office representation, onshore and offshore trust company formation and the administration of estates and trusts, together with our business affiliates;
Planning, drafting and effectuating creative asset protection techniques for the maintenance of family wealth, prior to and during litigious scenarios. This would include transfer and assignment of foreign and domestic assets into asset protection structures, including use of annuities, insurance, installment sales and other asset protection and deferral vehicles. Moreover, this includes negotiating and administrating matters with foreign banks, and trust and insurance companies affiliated with the firm.
Designing flexible, multi-tiered business and tax structures for all types of clients, including the choosing of the appropriate combination of jurisdictions, domestic and foreign entities, including multi-tiered structuring alternatives, while accounting for treaties, transfer pricing and branch profits tax issues ;
Advising on taxable and tax-free stock and asset merger and acquisition transactions of entities and background shareholders.
Advising on state and local income, documentary stamp tax, ad valorem, intangible, sales and use, and other areas of local taxation, including legislative and lobbying activities and litigation in various courts related to such items, including technical assistance advisory rulings;
Coordinating and managing private trust companies, the administration of estates and trusts, succession planning for family-owned businesses, and international estate planning for in-bound and out-bound United States and foreign business executives and closely-held entities, together with our international business affiliates;
Advising on sophisticated charitable giving techniques, including among other things, charitable remainder annuity trusts (CRATS), charitable remainder uni-trusts (CRUTS) and other techniques. This also includes wills, trusts, powers of attorney, medical directives, probate, drafting appointments of trustees, protectors, custodians and investment managers.

For more information about the experience and capabilities of our Domestic and International Taxation, Estate Planning, Government Filing Compliance, Asset and Creditor Protection, and Probate Group, please contact our partner, Ronald R. Fieldstone (rrf@fsdlawyers.com)



about us practice areas Our Attorneys contact us directions Southeastern Title Services, Inc.	Domestic and International Taxation, Estate Planning, Probate, Government Filing Compliance, and Asset and Creditor Protection The Domestic and International Taxation, Estate Planning, Government Filing Compliance, Asset and Creditor Protection, and Probate Group within our firm consists of licensed lawyers, Certified Public Accountants and former government employees with a broad range of practical, technical and business experience. Members of this group have extensive experience in sophisticated tax-driven corporate, real estate and varying business transactions. Generally stated, the firm's international legal services include, with the assistance of domestic and foreign tax counsel, supervising the formation and day-to-day operations of domestic and foreign companies; planning and coordinating investments into and out of the United States by nonresident and resident alien individuals, individual citizens and various types of business entities into real estate, closely-held businesses and other types of private and public businesses; structuring international joint ventures; coordinating and arranging domestic and international financing; and negotiating and drafting all types of tax-driven agreements and operative documents. The firm handles all aspects of international and domestic income, gift and estate, state and local, and compliance tax planning with individuals and business clients, including cash flow, budget planning and executive business decisions. Also, through Fieldstone, Lester, Shear & Denberg, LLP, we offer a Corporate Maintenance and Compliance Program whereby the firm also serves as professional registered agents offering fiduciary services with the highest level of personal care and attention, including allowing entities to use our offices and services for their day-to-day business and legal needs, including corporate maintenance, updating of annual reports and board meetings. Specifically, in this regard, the firm's domestic and international legal and compliances services include, among other things: Providing legal advice by, amongst and between our lawyers, clients, 3rd party affiliates (e.g., bankers and realtors), internal company counsel, and foreign tax counsel for multinational individuals and companies, including, supervising the formation of domestic and foreign companies and assisting in the opening of ancillary bank accounts with strategic bank alliance partners; Planning and coordinating investments in domestic and foreign real estate and other types of business ventures. This includes representing clients in the utilization of Section 1031 tax deferred exchange transactions, the Foreign International Real Property Tax Act (FIRPTA) withholding transactions and related planning opportunities, and contesting real estate tax assessments for commercial and residential properties; Structuring international joint ventures and franchises while focusing on placement of strategic operations in multiple jurisdictions; Coordinating and arranging domestic and international financing with strategic lending parties; Negotiating and effectuating agreements in all types of domestic and international transactions and on-going day-to-day projects and business issues, such as employment agreements, and liquidation and dissolution of business entities. Structuring implications of international, federal, state and local transactions and related corporate, partnership and individual taxation matters for all types of businesses, including, among others, mergers and acquisitions, executive and employee compensation, taxable and tax-exempt financing arrangements, and structured financing. This includes planning and drafting deferred compensation agreements, stock options, stock bonus plans, and planning with controlled foreign corporations (subpart- F income), passive foreign investment companies, and 367 “toll charges.” Representing domestic and international clients in tax litigation and controversy work before international, federal, state and local taxing authorities, including the seeking of private letter rulings from the Internal Revenue Service. Opining upon the special tax rules applicable to varying types of entity taxation, financial instruments and interaction with bilateral income and commerce treaties by, amongst and between the United States and other jurisdictions throughout the world, including the application and negotiations of Bilateral Treaties and Information Exchange Agreements; Advising on individual and business entity tax planning, as related to tax return positions and preparation. This includes compliance filings for domestic and offshore individuals, public corporations, closely held businesses, partnerships, limited liability companies, venture funds, trusts, charitable and private foundations, and tax-exempt organizations. Structuring tax planning during the initial, on-going and winding-up of multiple multi-national business areas, including, among others, real estate developments, restaurant chains, pharmaceutical companies, technology and other global business sectors; Advising on pre-immigration (e.g., non-resident alien) income, gift and estate tax planning, and business succession planning amongst family members and business partners; Maintaining family office representation, onshore and offshore trust company formation and the administration of estates and trusts, together with our business affiliates; Planning, drafting and effectuating creative asset protection techniques for the maintenance of family wealth, prior to and during litigious scenarios. This would include transfer and assignment of foreign and domestic assets into asset protection structures, including use of annuities, insurance, installment sales and other asset protection and deferral vehicles. Moreover, this includes negotiating and administrating matters with foreign banks, and trust and insurance companies affiliated with the firm. Designing flexible, multi-tiered business and tax structures for all types of clients, including the choosing of the appropriate combination of jurisdictions, domestic and foreign entities, including multi-tiered structuring alternatives, while accounting for treaties, transfer pricing and branch profits tax issues ; Advising on taxable and tax-free stock and asset merger and acquisition transactions of entities and background shareholders. Advising on state and local income, documentary stamp tax, ad valorem, intangible, sales and use, and other areas of local taxation, including legislative and lobbying activities and litigation in various courts related to such items, including technical assistance advisory rulings; Coordinating and managing private trust companies, the administration of estates and trusts, succession planning for family-owned businesses, and international estate planning for in-bound and out-bound United States and foreign business executives and closely-held entities, together with our international business affiliates; Advising on sophisticated charitable giving techniques, including among other things, charitable remainder annuity trusts (CRATS), charitable remainder uni-trusts (CRUTS) and other techniques. This also includes wills, trusts, powers of attorney, medical directives, probate, drafting appointments of trustees, protectors, custodians and investment managers. For more information about the experience and capabilities of our Domestic and International Taxation, Estate Planning, Government Filing Compliance, Asset and Creditor Protection, and Probate Group, please contact our partner, Ronald R. Fieldstone (rrf@fsdlawyers.com)

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