Whether you live abroad or own a company or property in another country, you need a U.S.-side CPA who coordinates your filings with your advisors there. Max Panchuk holds three passports, and that background supports the work.
U.S. citizens and residents are taxed on income from anywhere in the world, and foreign persons can owe U.S. tax on income and property in the United States. When people, income, or assets sit in more than one country, the filing rules overlap and are easy to miss.
We help you understand your U.S. filing responsibilities, including reporting for foreign income, accounts, businesses, trusts, and certain gifts or inheritances. We also handle U.S. tax matters for nonresident individuals and foreign owners of U.S. property. Where needed, we coordinate with advisors in the other country and look for relief from double taxation.
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The structural moves that compound on a 5-10 year grow-then-exit horizon, engineered, documented, and stress-tested years before a transaction is on the table.
When a foreign person sells U.S. real estate, the buyer must withhold part of the price for the IRS under a law known as FIRPTA, generally 15 percent of the sale price, and some states withhold as well. We can apply to reduce the withholding before closing, so that less cash is held back.
U.S. persons whose foreign accounts add up to more than a set total must report them every year. Missed reports can carry large penalties. We help you understand the IRS’s options and which one fits your facts.
U.S. owners of foreign companies must file additional reports and may owe U.S. tax on the company’s income. We coordinate those filings, the tax treaty between the countries, foreign tax credits, and part-year returns with your advisors in the other country.
Giving up U.S. citizenship or a long-held green card can trigger an exit tax on gains you have not yet realized. We estimate the cost, review timing and filing requirements, and coordinate the final year’s returns before you decide.
A Canadian seller of U.S. real estate faced standard FIRPTA withholding plus state withholding. Through a Form 8288-B application, a treaty election, and timely filing, we reduced federal withholding and structured the gain under the treaty. “They handled three countries of tax obligations in a single engagement.”. Canadian Seller, Vancouver
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Standard FIRPTA withholding is 15% of the gross sale price, plus applicable state withholding. California Form 593 withholding depends on the facts. Exemptions and alternative gain-based computations can apply. It is not a universal 3.33 percent of sale price. For many sellers, default withholding exceeds the actual tax owed. An 8288-B withholding certificate filed before close can reduce federal withholding toward expected tax.
California Form 593 can apply on sales of California real property by nonresidents. The amount is not a universal 3.33 percent of sale price. Exemptions and alternative gain-based computations exist. We model federal FIRPTA and California Form 593 together before close.
We are licensed CPAs acting as year-round advisors. Structure, cash, and filings stay in one file. Exit-tax modeling for expatriation is planning before anyone files Form 8854.
Streamlined filing is generally for non-willful failures. Voluntary disclosure is a different path, often used when willfulness is a concern. Penalty results and any criminal-referral risk depend on the facts, the program, and IRS discretion. We do not recommend a path without a full conduct review, and we do not describe either program as categorical criminal-referral protection.
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