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Strategic Tax Advisory
U.S. and international tax advisory for high-impact decisions: before you invest, sell, relocate or expand.
What it includes
- Transaction and sale planning, including FIRPTA (Foreign Investment in Real Property Tax Act) withholding for foreign sellers.
- Nonresident taxation and withholding.
- Foreign companies owned by U.S. persons: CFC (Controlled Foreign Corporation), NCTI (Net CFC Tested Income), Subpart F and PFIC (Passive Foreign Investment Company).
- International compliance strategy (FBAR, Forms 5471 and 5472, Streamlined procedures) before it is executed.
- Confidential tax memos.
Who carries it out
PAG defines the strategy. Preparation and compliance are performed by Tax Planning Plus; if there is already exposure or IRS contact, representation is handled by SOLON.
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