SERVICES

How Auric Private Client Advisory LLC works

Auric Private Client Advisory LLC advises U.S. and non-U.S. private clients, trustees, and family offices on cross-border U.S. tax compliance and reporting. The practice concentrates on the international information returns that general practitioners see rarely and that carry the heaviest penalties for omission. The practice is led by Milan Solarz-Patel, a former senior trial attorney with the IRS Office of Chief Counsel, and every engagement has his direct involvement. Most engagements fall into one of the five areas described below.

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International information returns

U.S. persons with foreign accounts, entities, or investments, and foreign persons with U.S. activities, must file a series of information returns alongside their income tax returns. Each is a stand-alone filing with its own penalty regime, and most carry a penalty of $10,000 or more for a late or incomplete form, regardless of whether any tax is due. We prepare these returns, review returns prepared by others, and coordinate with the client's Form 1040 or Form 1120 preparer so that the information returns and the income tax return tell the same story. Our note on Form 5472 for foreign owners of U.S. LLCs illustrates the approach.

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Federal tax preparation and advice

We prepare federal returns for clients whose situations turn on international reporting: U.S. citizens and residents living abroad, non-resident aliens with U.S. real estate or business interests, U.S. persons with foreign real estate or businesses, and U.S. beneficiaries or grantors of foreign trusts. The planning questions that arise most often are summarised in Cross-Border Planning Issues Every U.S. Investor Should Know and Estate Planning Challenges for U.S. Families with Overseas Assets.

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Foreign trust reporting

We act as reporting counsel to trustees, U.S. owners, and U.S. beneficiaries of foreign trusts. That work includes Form 3520 and Form 3520-A, the Foreign Grantor Trust and Foreign Non-Grantor Trust Beneficiary Statements that trustees must furnish, and the distributable net income and undistributed net income computations that determine how a distribution is taxed. For an introduction to the classification questions, see What Type of Trust Do You Have? and U.S. Taxation of Foreign Grantor and Non-Grantor Trusts.

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IRS offshore compliance and voluntary disclosure

For taxpayers who have not filed, or who have filed incompletely, we assess eligibility and prepare submissions under the Streamlined Foreign Offshore Procedures, the Streamlined Domestic Offshore Procedures, the Delinquent FBAR Submission Procedures, and the Delinquent International Information Return Submission Procedures. The choice among these procedures depends on residence, the reason for the non-filing, and the exposure under each; our overview of the Streamlined Filing Compliance Procedures explains the framework, and our IRS Streamlined Filing Compliance Procedures page summarises both procedures with a downloadable one-page guide.

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Expatriation and alternative citizenships

We advise U.S. citizens and long-term residents who are considering renunciation or a second citizenship, including the Section 877A exit-tax analysis, Form 8854, and the planning that should precede the appointment at the consulate. Recent notes cover Turkish citizenship by investment and global residency and citizenship options.

To discuss an engagement, please use the Contact page.