WHO WE SERVE

Individuals, Trans-national Legal Entities & Family Offices

High-net-worth individuals, trans-national legal entities, and family offices navigating complex cross-border structures.

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Cross-border structures create exposure across tax, regulatory, and financial reporting obligations. Decisions made today are often assessed later by examiners, legal advisors, or courts, frequently with more context than was available at the time.

Common needs:

  • Understanding exposure in complex, cross-border tax matters
  • Independent analysis of tax positions in disputes and investigations
  • Structuring and evaluating cross-border arrangements in legal contexts
  • Preparing for audit, review, and controversy proceedings
  • Navigating IRS disclosure and compliance considerations

"Foodman CPAs & Advisors and my legal team assisted me with submitting the proper narrative statement to the IRS regarding my options related to underreported foreign assets. The explanations provided by Foodman and my legal team together with all the actions taken to become compliant were successful."

— High-net-worth Individual, Tamarindo, Costa Rica

How the work applies

In Practice

Each engagement is shaped by the individual's cross-border structure, tax position, and reporting obligations.

A High-Net-Worth Individual in Colombia: IRS Substitute for Return

A high-net-worth U.S. citizen residing in Bogotá, Colombia received an IRS notice stating that a Substitute for Return had been filed on his behalf. The IRS calculated tax, penalties, and interest based on income reported by third parties, without the benefit of deductions, credits, or position documentation the individual could have submitted.

Foodman CPAs & Advisors represented the individual before the IRS, assessed the positions available, and submitted documentation to support a more accurate return. The IRS assessment was reduced by more than 50%.

Services applied:

  • IRS Disclosure and Compliance Strategy
  • Forensic Tax Review and Exposure Analysis

Topics addressed:

  • IRS Substitute for Return
  • Cross-border tax compliance
  • IRS representation and examination response

This is one example of our work helping a client. For more, search “Financial Institutions” (under Industry filter) in our Insights Hub.

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