TAX LAW
THEVOZ & Partners advises clients on complex U.S. and international tax matters involving cross-border investments, corporate structures, private wealth planning, and regulatory obligations. Our practice focuses on strategic tax advisory, risk management, and the coordination of U.S. tax rules with foreign legal and financial environments.
We assist U.S. and international clients, including corporate groups, investors, family offices, and high-net-worth individuals, with tax issues arising from transactions, international structures, wealth planning, and regulatory obligations. Our work frequently involves technically complex U.S. tax regimes, including PFIC, CFC, and FATCA frameworks, and is typically carried out in coordination with foreign advisors, accounting firms, and financial institutions.
Our tax practice focuses on complex cross-border advisory and tax risk management, rather than routine tax filing services.
Transactional Tax Advisory
M&A, Acquisitions & Investments
We advise clients on the tax aspects of corporate transactions, acquisitions, and cross-border investment structures involving the United States. Our work includes tax structuring for mergers and acquisitions, inbound and outbound investments, and cross-border corporate reorganizations. We regularly assist investors, private equity sponsors, family offices, and international corporate groups in structuring acquisitions of U.S. businesses, real estate assets, and investment platforms.
Our advisory focuses on designing efficient and sustainable ownership structures that address U.S. tax exposure at both the investor and entity level. This includes the selection and coordination of appropriate holding entities, the structuring of investment vehicles, and the analysis of withholding, repatriation, and exit considerations in cross-border investment scenarios.
These matters frequently involve technically complex U.S. tax regimes applicable to international structures, including Passive Foreign Investment Company (PFIC) rules and Controlled Foreign Corporation (CFC) considerations. We assist clients in evaluating the implications of these regimes for multinational ownership structures, investment funds, and corporate groups, ensuring that U.S. tax requirements are properly integrated with commercial objectives and applicable foreign legal and regulatory constraints.
Private Client & Estate Tax Planning
Trusts, Estates & Family Wealth
We advise individuals, families, and family offices on cross-border wealth structuring and estate tax planning involving the United States, particularly where assets, beneficiaries, or trustees are located in multiple jurisdictions.
Our work includes the structuring and taxation of U.S. and non-U.S. trusts, estate and gift tax planning, and the design and implementation of long-term succession strategies for internationally held assets. We regularly assist clients in organizing family wealth structures that address both U.S. transfer tax exposure and international tax considerations, including the use of trust arrangements, holding vehicles, and governance frameworks adapted to multigenerational planning.
We also advise trustees, beneficiaries, and family offices on the U.S. tax treatment of trust distributions, reporting obligations, and the interaction between trust structures and U.S. income, estate, and gift tax regimes. Our practice frequently involves advising on complex situations where beneficiaries reside in different jurisdictions or where U.S. persons participate in foreign trust structures.
These matters often require close coordination between U.S. tax rules and foreign legal and tax regimes, particularly in Europe, as well as collaboration with local advisors, fiduciaries, and financial institutions to ensure that wealth structures remain compliant, efficient, and sustainable over time.
Within Cross Border Tax Planning, we specialize in:
U.S. Persons Operating Abroad
Foreign Persons & Entities’ Activities in the U.S.
Tax Disputes & Risk Management
We represent clients in U.S. tax disputes and complex tax risk matters, particularly where issues arise in cross-border transactions, international investment structures, or private wealth arrangements involving the United States.
Our work includes advising and representing clients in IRS examinations, administrative proceedings, and litigation before the United States Tax Court and other federal courts. We assist taxpayers in disputes concerning the tax treatment of international structures, transactions, and reporting obligations, and provide strategic support in matters where tax issues intersect with commercial litigation, shareholder conflicts, or trust disputes.
We also advise clients on assessing, documenting, and defending tax positions adopted in corporate transactions, investment structures, and cross-border reorganizations. Our approach focuses on evaluating potential exposure, preparing defensible legal positions, and managing interactions with tax authorities in a structured and strategic manner.
Many matters involve technically sensitive issues related to U.S. international reporting obligations, including Form 3520, Form 3520-A, and FBAR filings, as well as disputes concerning penalties associated with these reporting requirements. We assist clients in responding to IRS inquiries, evaluating potential defenses, and addressing penalty assessments arising from alleged reporting failures. These matters are often handled in coordination with U.S. tax counsel, accounting firms, and foreign advisors, ensuring that both the legal and technical aspects of complex cross-border tax disputes are properly addressed.
Within Tax Controversy, we specialize in:
Cross-Border Tax Compliance & Regularization
We assist clients in addressing U.S. tax reporting obligations and regularizing historical tax exposure arising from cross-border situations.
Our work includes advising U.S. and international clients on U.S. reporting frameworks, FATCA-related obligations, and the remediation of historical non-compliance. We regularly assist individuals in becoming compliant with U.S. tax rules through Streamlined Filing Compliance Procedures and other voluntary disclosure mechanisms, particularly where U.S. tax obligations arise unexpectedly due to citizenship, residence, or international financial holdings.
These matters are typically addressed in conjunction with broader tax planning and long-term structuring considerations.
Within Tax Compliance, we specialize in:
For Frequently Asked Questions about Streamlined Filing Procedures
Within Relinquishment of U.S. Nationality, we specialize in:
International Tax
Our practice regularly involves international tax matters arising from cross-border investments, corporate structures, and private wealth arrangements involving the United States and multiple jurisdictions.
We advise U.S. and international clients on the U.S. tax implications of international ownership structures, foreign entities, and global investment platforms. Our work frequently includes the analysis of U.S. international tax regimes applicable to foreign corporations, investment vehicles, and multinational ownership structures, including issues related to PFIC, CFC, and FATCA frameworks.
We also assist clients in navigating the interaction between U.S. tax law and foreign legal and tax regimes, including the application of tax treaties, international reporting obligations, and the tax consequences of cross-border asset ownership. These matters often require coordination with foreign counsel, accounting firms, financial institutions, and fiduciary professionals to ensure that international structures remain compliant and tax-efficient over time.
Our experience in international tax matters allows us to advise clients on both the structuring and ongoing management of cross-border investments and wealth arrangements, as well as the resolution of disputes or reporting issues involving multiple jurisdictions.
THEVOZ & Partners specializes in the area of Tax Law
Tax Minimization
Ideally, the same income should not be taxed twice. However, that is not often the case. Unfortunately, double taxation routinely occurs in international investments, cross-border business operation or even simply in scenarios where a U.S. person moves abroad. Luckily, our professionals can help you legally plan around your tax responsibilities both at home and abroad. As Judge Learned Hand so eloquently put it: "Any one may so arrange his affairs that his taxes shall be as low as possible; he is not bound to choose that pattern which will best pay the Treasury; there is not even a patriotic duty to increase one's taxes." Gregory v. Helvering, 69 F.2d 809, 810 (2d Cir. 1934) (emphasis added). Let THEVOZ & Partners assist you with minimizing your tax burden and ensuring that you are maximizing the tax efficiency of any given transaction.
In the international context, it is important to have professional representation to help you navigate and plan in the context of the relevant income and estate tax treaties that may be in effect. As a transatlantic firm THEVOZ & Partners are experts on tax treaties that may be relevant to you and your business. We can also help advise you when rule changes impact your tax liability.
Controversy Experience
Our attorneys have litigated cases before the Tax Court and they can handle a case through every step in the process. Litigation may start with an audit but it does not end until collection. It is important to have attorneys that understand the complete process from start to finish so that they can get you the best result possible. It is also important to have attorneys that have an understanding of the tactics that the IRS uses to examine and collect from taxpayers.
Compliance
The US system has numerous information returns and failure to property file these can have adverse effects on taxpayers. For instance, failing to file information returns for foreign accounts can lead to penalties of 50% or greater on the high balance in the account. And many taxpayers are unaware that they may be responsible for filings FBARs on the accounts of their foreign businesses.
IRS offers several programs to help noncompliant taxpayers to become in compliance. Walking through these procedures alone can be daunting and even overwhelming. However, we believe that taxation should never get in the way of your personal and professional aspirations. That's why we are here to help. Let us deal with the messy details so that you can spend more time focusing on what really matters to you.
Olivier Thevoz
Partner and Founder
Olivier Francioli
Partner
Sandra Ezri
Of Counsel
Steve Tannenbaum
Partner
LATEST ARTICLES
THEVOZ & Partners is an international law firm best known for its practice in international tax, civil litigation, and business transaction structuring. We are committed to providing our clients with tailored and competent services.
New York
1239 Broadway
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New York, NY 10001
Phone +1 (315) 201-2230
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Rue Etraz 4
Case Postale
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Honolulu, HI 96813
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