Tax Services
Tax Law & Business Services
Domestic Tax
Jenny advises clients on a variety of U.S. federal income tax issues including personal tax issues, property sales, business sales and tax planning for business formations and reorganizations. There are also many situations where it is necessary to know how an item should be treated for income tax purposes, such as the payment of a legal settlement, an unusual financial contract, the treatment of energy incentives and other less common situations. Jenny will help you figure out how different forms of compensation, property and other payments you might receive should be treated for U.S. tax purposes and, where possible, she will suggest structuring options to minimize the tax burden.
International Tax
The U.S. tax provisions applicable to cross-border transactions and situations are among the most complex in the Internal Revenue Code and can be a minefield for the uninformed. In addition to review of applicable U.S. rules, an international situation typically requires analysis and interpretation of tax treaties between the U.S. and the jurisdictions involved. Jenny will work with lawyers in the foreign jurisdiction to arrive at the optimal tax structure or resolution for the circumstances. Jenny has spent years practicing in this nuanced and complicated area of tax law and is not ashamed to admit that she actually enjoys the complexity.
Small Business
Jenny works closely with small business owners and entrepreneurs on everything from deciding which type of entity is most appropriate to planning for sale of the business, exit strategies and succession planning. Jenny builds long-term relationships with her clients and they know she’s there when they need a contract drafted, need an employment agreement or review of a contract arising in their business dealings. She gives practical and clear advice on any number of business issues and situations that can arise.
General Tax Services
Guidance on choice of entity
Structuring of business acquisitions and sales
Individual tax review, tax planning and consultation
International Tax Planning
Inbound and outbound asset transfers and business reorganizations
Whenever business reorganizations cross the U.S. border, careful attention to the structure and potential tax implications is essential. Special tax rules can apply to transfers of assets to entities outside of the U.S. Likewise, investment into the United States by nonresidents can have significant and sometimes surprising tax implications. Jenny will review the particulars of your business, its assets, your tax situation and your goals to help you determine the most tax-efficient and appropriate structure for your transaction.
Foreign business ventures and foreign investment
When you enter into a foreign business venture, it is important to understand the U.S. tax implications to you from doing so. There are a number of complex rules, designed to combat income tax deferral and evasion, and appropriate tax planning can avoid or mitigate potentially harsh U.S. tax ramifications to US taxpayers from the foreign venture or investment. Jenny is familiar with these rules and can help you navigate around them.
Foreign acquisition of U.S. real estate
Special tax rules apply to the sale of U.S. real estate interests by foreign persons. These complex rules alter the otherwise beneficial U.S. tax treatment that applies to the sale of capital assets held by foreign persons. Jenny can analyze how these rules apply to your situation and can help you structure around them, where possible.
Foreign asset and financial account reporting
U.S. taxpayers are expected to report ownership of foreign financial assets. Detailed rules enumerate the assets to be reported, the type of reporting required and the penalties for not reporting them. The penalties are serious and often catch people by surprise. Jenny can help determine whether your assets are subject to these reporting requirements and can help find mitigating solutions for noncompliance.
Immigration tax counseling and tax planning
People immigrating into the United States (or who spend sufficient time here to become residents for tax purposes) often are unaware that acquiring U.S. tax residency brings all of their assets worldwide into the United States tax net. Careful tax planning in connection with the immigration can avoid unnecessary U.S. tax liability. Jenny works with people during the immigration process to ensure that no more U.S. tax is levied on their foreign assets than is absolutely necessary.
Emigration tax counseling and tax planning
The U.S. has rules designed to tax the property of U.S. citizens and long-term residents who expatriate, before such assets permanently leave the U.S. taxing jurisdiction. There are also special tax rules applicable to certain outbound business migrations. Jenny can assess whether and how these rues might apply to your emigration or business relocation and help you take steps to mitigate the impact of them.
Tax counseling for U.S. persons living abroad
Although there are treaties and tax rules to mitigate double taxation, U.S. taxpayers are generally subject to tax in the United States on all of their income worldwide. U.S. taxpayers living abroad are likely to be subject to the foreign financial reporting rules as well. Jenny counsels U.S. taxpayers who reside abroad on the tax implications of their situations and options for managing their affairs in a tax-efficient manner.
Tax consultation for U.S. resident aliens
Foreign nationals taking up residence in the United States often are unaware that acquiring U.S. residency brings all of their assets worldwide into the United States tax net. Foreign nationals are also likely to have foreign financial assets subject to U.S. tax reporting requirements, with potentially significant penalties imposed for noncompliance. Jenny advises foreign nationals living in the US or considering relocating to the US on the application of U.S. tax rules to their foreign and U.S. assets and applicable tax reporting requirements.
Tax treaty interpretation
The United States has income tax treaties designed to avoid double taxation in the context of cross-border circumstances with most countries. The provisions in these treaties are very technical and complex, and it is important to understand how they apply and how they interact with the provisions of local law in the contracting countries. Jenny helps clients understand how an applicable treaty impacts them and their U.S. taxes, providing advice on how best to take advantage of the relevant treaty to reduce liability.
Cross-border payroll tax compliance issues
Jenny has helped bring foreign employers of U.S. taxpayers to come into compliance with U.S. payroll withholding requirements and has likewise assisted U.S. employers of foreign employees and interns in determining their withholding requirements. The rules can differ depending on the type of entity and the circumstances of the employee’s presence in country.
General Consultation
Jenny consults with people in a variety of circumstances involving the intersection of US and foreign tax rules and helps them see what rules might apply to them, engage in tax planning and tax mitigation as needed.
Small Business Services
Entity Formation
There can be significant legal and tax ramifications to the type of entity you choose for your business. As a tax and business lawyer, Jenny can help you understand your choices and their implications. In addition to handling the required filings to form the entity, Jenny can prepare the necessary organizational documents and agreements for your new business.
Restructuring
As a business grows or needs change, it may be appropriate to change corporate or capital structure, acquire new lines of business and or enter into a business combination with another. Jenny has worked on many business reorganization transactions and can advise on structuring options and tax implications as well as drafting the necessary documentation.
Asset and Business Sales
There are many ways to structure the sale of a business. Jenny can help you navigate the legal and tax ramifications of the different options available to you and can assist in the drafting and review of purchase and sale agreements and related contracts.
Succession Planning
Your business may be your most valuable asset and decisions related to an owner’s exit and how the business is to be continued are important, with significant legal and tax ramifications. Jenny can help you discuss these decisions at inception or at a later stage and to devise a practical and tax-efficient strategy for your transition.
Compensation
There are a variety of ways to structure compensation of key personnel, each with different tax and legal implications. Jenny will help you sift through the different options and implement a plan that works for you and your business.
Contract Drafting, Review and Negotiation
Jenny can draft contractual language for your business dealings and review and negotiate contracts before you sign to ensure you are protected.