INTERNATIONAL TAX 

Randall & Associates solve complex tax problems for clients all over the globe. Our clients include private equity funds, publicly traded corporations, partnerships and individuals.

Offshore Compliance & FATCA

International tax compliance is becoming a hot-button issue for our clients that operate abroad. We’ve helped hundreds of clients successfully navigate offshore compliance and FATCA (FinCEN 114) requirements such as FBAR, SDOP, SDDP, FORM 8938, FORM 5471 and FORM 8865. We've helped hundreds of clients successfully navigate the Offshore Voluntary Disclosure Procedure (OVDP) and the related Streamlined Foreign (SFOP) & Streamline Domestic (SFOD) Offshore Procedures. 

International Tax Planning 

As the regulatory and corporate landscape changes it is common for our clients to require tax planning for their businesses and families. Our tax planning services give our clients the tools they need to avoid unnecessary tax, create profitable structures for their businesses or funds, and protect their assets. We provide real solutions for in-bound and out-bound investments and create tax structures that are most beneficial from tax perspective.

International Tax Arbitration & Litigation 

Sometimes arbitration or litigation is required to resolve tax issues. We’ve successfully litigated tax cases for our clients in U.S. Tax Court, U.S. District Court, Bankruptcy Court and U.S. Court of Claims.

 

SERVICES 

  • International Tax Planning

  • FATCA & Offshore Compliance

  • FBAR Submissions

  • OVDP - Offshore Disclosures

  • Streamline Foreign Disclosures

  • Streamline Domestic Disclosures

  • International Tax Audits

  • Kovel Letter Representation

  • Legal Tax Opinions

*UPDATE: The OVDP or Offshore Voluntary Disclosure Program has been eliminated by the IRS. It is important to meet with an experienced international tax attorney if you may have been willfully hiding or not disclosing foreign assets so that you can eliminate the risk of criminal prosecution and get back into compliance the right way.

CLIENTS

U.S. Citizens.                                        U.S. Persons Living Abroad           Foreign Investors                              Multi National Companies              Private Equity Funds.                     Publicly Traded Companies.             REITS & Family Offices.              Investment Advisors                      Closely Held Corporations (Private)  Partnerships                             Accredited Investors