International Taxation

Andreozzi Bluestein LLP provides representation and guidance to individuals with interests in foreign accounts and businesses.

International Taxation

Andreozzi Bluestein LLP provides representation and guidance to individuals with interests in foreign accounts and businesses.

We represent an extensive international client base of individuals and businesses in a wide range of issues including foreign bank account reporting, Subpart F and controlled foreign corporation issues, residency and domicile matters, transfer pricing issues, and foreign trust matters.  This includes taxpayers who have moved abroad, and those residing in the United States with interests in foreign bank accounts, investment accounts, businesses and other assets held abroad. This also includes individuals under examination for late filing or failing to file information reports required under the Internal Revenue Code (Title 26) or the Bank Secrecy Act (Title 31), such as the Foreign Bank Account Report (FBAR).  Our firm’s criminal and civil tax litigation groups are led by attorneys with decades of combined experience with Internal Revenue Service Office of Chief Counsel and the United States Department of Justice.

Foreign Business Information Reporting

U.S. tax law requires substantial information reporting for foreign corporations, partnerships, trusts and certain foreign investments.

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FBAR (Foreign Bank Account Reporting) & FATCA (Foreign Account Tax Compliance Act)

U.S. persons, this includes both individuals and businesses, are subject to substantial information reporting requirements.

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Voluntary Disclosure Representation

Andreozzi Bluestein LLP can assist in determining the reporting obligations and determine the proper IRS voluntary disclosure initiative for a client’s specific circumstances.

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Transfer Pricing

Transfer pricing is an important issue for related companies transacting business internationally.

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Permanent Establishment

In today’s global market, businesses are focusing more resources on effectively managing and organizing permanent establishments. Likewise, taxing authorities, including the IRS, are becoming more aggressive in addressing permanent establishment issues.

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Residency/Domicile Issues

Domicile is a common-law term which refers to a person’s fixed or permanent living place in which the person intended to live indefinitely or intends to return.

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