Areas of Practice
Tax Planning - International and Domestic
We advise clients navigating the intersection of U.S. and foreign tax systems, with a focus on cross-border individuals and businesses whose lives, families, or operations span more than one jurisdiction. Our practice combines technical depth in the Internal Revenue Code with practical experience applying tax treaties, foreign tax regimes, and information-reporting rules.
Cross-Border Individuals
Pre-immigration planning for individuals relocating to the United States, including basis step-up strategies, accelerated income recognition, and restructuring of foreign holdings before establishing U.S. tax residency
Expatriation and exit-tax planning under IRC §§ 877 and 877A, including covered-expatriate analysis and mitigation strategies
Residency and domicile planning, including treaty tie-breaker analysis and coordination of federal and state residency positions
Foreign account and asset reporting, including FBAR (FinCEN 114), FATCA (Form 8938), Forms 3520 and 3520-A for foreign trusts and gifts, Form 5471 for foreign corporations, and Form 8621 for PFICs
PFIC planning, including QEF and mark-to-market elections and restructuring of foreign mutual fund and investment holdings
Subpart F and GILTI planning for U.S. individual shareholders of controlled foreign corporations, including § 962 elections and check-the-box restructuring
Foreign tax credit optimization, treaty-based return positions, and resourcing strategies
Cross-border estate, gift, and trust planning, including planning for non-resident aliens with U.S. situs assets, dynasty and offshore trust structures, and use of estate and gift tax treaties
Voluntary disclosure, Streamlined Filing Compliance Procedures, and delinquent international information return submissions
Cross-Border Businesses
Inbound structuring for foreign businesses, investors, and family offices entering the U.S. market, including FIRPTA planning, blocker structures, and treaty-qualified holding companies
GILTI, FDII, BEAT, and Subpart F planning, including high-tax exclusion elections, § 962 elections, and entity classification (check-the-box) strategies
Permanent establishment analysis and treaty-based reduction of withholding on dividends, interest, royalties, and service fees
Cross-border M&A and reorganizations, including § 367 planning, gain-recognition agreements, and post-acquisition integration.
Repatriation planning and previously taxed earnings and profits (PTEP) tracking
U.S. withholding compliance under Chapters 3 and 4, including Forms W-8, 1042, 1042-S, and FATCA classification
Domestic Tax Planning
Choice of entity and conversion planning for closely held businesses
Federal estate, gift, and generation-skipping transfer tax planning, including dynasty trusts, GRATs, SLATs, and intra-family lending
Real estate tax planning, including § 1031 like-kind exchanges, qualified opportunity zone investments, and REIT structures
State and local tax planning, including multi-state residency, pass-through entity tax elections, and nexus analysis
Charitable planning, including private foundations, donor-advised funds, and charitable remainder and lead trusts
IRS controversy support, including audit defense, voluntary disclosures, and private letter ruling requests
Tax Audits
We represent individuals, businesses, and fiduciaries in examinations, appeals, and collection matters before the Internal Revenue Service, state tax agencies, and local taxing authorities. Our goal is to resolve disputes efficiently — at the earliest stage possible — while protecting clients from unnecessary tax, penalties, and disruption to their financial lives and operations.
Audits & Examinations
IRS examinations at all levels, including correspondence audits, office audits, and field examinations conducted by Revenue Agents
Large and complex case examinations, including LB&I audits, coordinated industry issues, and IDR response strategy
High-income and high-wealth individual examinations, including the IRS's Global High Wealth program
Partnership audits under the centralized partnership audit regime (BBA), including push-out elections, partnership representative matters, and modification procedures
Employment tax audits, including worker classification disputes (§ 530 relief), trust fund recovery penalty investigations, and payroll tax assessments
International examinations, including audits involving foreign accounts, foreign entities, transfer pricing, FBAR, and Forms 5471, 8938, 3520, and 8865
Estate and gift tax audits, including valuation disputes, defective grantor trust issues, and adequate disclosure questions
State and local audits, including residency examinations, sales and use tax audits, nexus disputes, and pass-through entity audits
Fashion, Apparel & Textile Law
Fashion law is a little bit like the Wild West. There’s a lot of potential, but the rules can be convoluted and vague at best. Protecting a brand or even a single design involves intellectual property, copyrights, trademarks, and patents. A successful case requires creativity and flexibility. Harris Ingram represents boutique design houses like Marta and Thorne, individual designers like Mara Bond, and illustrators and graphic designers. We protect their products against copycats large and small, and guide them through manufacturing ethics and labeling laws.
Intellectual Property
We advise globally connected families on the structuring, administration, and transfer of wealth across borders. Our clients include U.S. citizens living abroad, non-U.S. persons with American family members or U.S. situs assets, dual nationals, mixed-nationality couples, and multi-generational families whose assets, beneficiaries, and trustees sit in different jurisdictions. We design plans that work under U.S. transfer tax rules while accounting for forced heirship, civil law succession, foreign trust recognition, and the practical realities of moving wealth across borders.
Planning for U.S. Persons with Foreign Connections
U.S. citizens and residents living abroad, including coordination of U.S. estate, gift, and GST tax planning with the succession and inheritance regimes of the country of residence
Foreign asset structuring, including treatment of foreign real estate, foreign retirement accounts, foreign life insurance, and foreign business interests under U.S. transfer tax and income tax rules
PFIC, CFC, and foreign trust considerations in the design of estate plans involving offshore holdings
Use of foreign tax credits against U.S. estate tax under applicable estate and gift tax treaties
Coordination with foreign counsel on wills, succession documents, and probate proceedings in multiple jurisdictions
Planning for Non-U.S. Persons (Inbound Planning)
Pre-immigration estate planning for individuals expected to become U.S. domiciliaries, including pre-residency gifting, drop-off trusts, and basis-step-up strategies
Non-resident, non-domiciliary planning for foreign individuals holding U.S. situs assets, including U.S. real estate, U.S. securities, and interests in U.S. businesses
FIRPTA planning and use of foreign and domestic blocker structures to manage U.S. estate tax exposure on U.S. real property
Foreign grantor trusts funded before U.S. residency, including planning for the five-year lookback and post-death conversion to foreign non-grantor trust status
Dynasty planning for foreign families with U.S. beneficiaries, including drop-off and accumulation trust design to mitigate throwback tax exposure
Mixed-Nationality Families & Cross-Border Couples
Planning for mixed-citizenship spouses, including the limited estate tax marital deduction available to non-citizen spouses and the use of qualified domestic trusts (QDOTs)
Lifetime gifting strategies between spouses of different citizenship, including the increased annual exclusion for gifts to non-citizen spouses
Coordination of community property, separate property, and forced heirship regimes across jurisdictions
Prenuptial and postnuptial agreements with cross-border tax and succession considerations
Expatriation & Departure Planning
Pre-expatriation gifting and trust funding for U.S. citizens and long-term residents planning to relinquish status
Covered expatriate analysis and exit tax planning under §§ 877A and 2801
§ 2801 succession tax planning for U.S. beneficiaries of covered expatriates, including use of non-grantor trusts and gift-splitting strategies
Coordination of expatriation with succession planning in the destination country
Tax Collections & Resolution
Installment agreements, including streamlined, non-streamlined, and partial-payment arrangements
Offers in compromise based on doubt as to collectibility, doubt as to liability, and effective tax administration
Currently not collectible status and hardship determinations
Collection Due Process (CDP) hearings and equivalent hearings, including challenges to liens and levies
Lien withdrawal, release, discharge, and subordination
Levy release and wage and bank levy defense, including economic hardship claims
Trust fund recovery penalty assessments and responsible-person disputes
Innocent spouse relief under § 6015, including traditional, separation of liability, and equitable relief claims
Passport revocation matters under § 7345 involving seriously delinquent tax debts
Bankruptcy and tax, including discharge analysis and coordination with bankruptcy counsel