Practice Areas

Our practice is divided into two distinct groupings: (1) California Cross-Border Tax Practice; and (2) US and International Cross-Border Tax Practice.

California Nonresident Tax Planning – (1) California Cross-border Lifestyle Planning; (2) Information Disclosure Management (“Staying Below the Radar”); and (3) Asset and Income Restructuring

FTB Form 4600 Tax Return Requests and Residence Inquiries – (1) Response to Residence Status Inquiries; (2) Response to Tax Return Requests; and (3) Residence Tax Audit Defense

California Residence Tax Audits – (1) Tax Audit Management; (2) Evidence Preparation; (3) Development of Legal Arguments

Tax-Efficient Structuring (or Restructuring) of California Vacation Home Ownership – (1) Avoids Disclosure of California Home Ownership; (2) Avoids Filing Individual Tax Return for Rental Income; (3) Avoids Nonresident Withholding Tax and Individual Tax Return on Sale; (4) Avoids Probate at Death of Each Owner

Nonresident Investors in California Rental Property - (1) Avoid Disclosure of Rental Property Ownership; (2) Avoids Filing Individual Tax Return for Rental Income; (3) Avoid California Nonresident Withholding Tax and Filing of Individual Tax Return on Sale; (4) Avoid Probate at Death of Each Owner

Nonresident Investors in Entities Doing Business in California – (1) Structuring to Avoid Filing Individual Nonresident Tax Return; (2) Entity Selection, Structuring, Set-up, Capitalization and Operation; (3) Drafting of Agreements

California Tax Planning for “Nomadic” Lifestyles – (1) Special California Tax Planning Considerations of Nomadic Lifestyles; and (2) Planning to Avoid Surprise Residence Issues

California Tax Planning For “Mixed-Residence” Couples – (1) Community Property Law Issues; (2) Avoid Nonresident Spouse Tax Return Filing; (3) California Compliant “Mirror” Pre-Nups and Post-Nups

California Pre-Residence Tax Planning – (1) Planning for Differences in Tax Systems; (2) Pre- and Post-Arrival Implementation; (3) Early Departure Tax Planning

Departures from California, Including Changes of Domicile and/or Tax Residence – (1) Changes of Tax Residence; (2) Changes of Tax Domicile; (3) “Safe-Harbor” Employment-Related Absences

California Income Tax Audits and Appeals – (1) Tax Audit Management; (2) Response to Notice of Proposed Assessment; (3) Appeals to CA Office of Tax Appeals

Planning to Avoid US Income Tax Residence – (1) Closer Connection Statements; (2) Substantial Presence Test Calculations; (3) Tax Treaty “Nonresident” Status

Nonresident Tax Planning for Cross-Border Investments – (1) Coordination with Home Country Law; (2) Income Tax Treaty Planning; (3) International Estate Planning; (4) Joint Venture Investments; (5) Probate Avoidance

Nonresident Tax Planning for Cross-Border Business Operations - (1) Coordination with Home Country Law; (2) Entity Selection, Structuring, Set-up, Capitalization and Operation; (3) Drafting of Agreements

Pre-Residence US Tax Planning – (1) Planning for Differences in Tax Systems; (2) Pre- and Post-Arrival Implementation; (3) Early Departure Tax Planning

“Dual Resident” Tax Planning – (1) Tax Treaty Residence “Tie-Breaker” Rules; Planning for “Treaty Nonresidents;” (2) US Information Reporting Obligations

“Dual Citizenship” Tax Planning – (1) US Tax Implications of US Citizenship; (2) Pre-Citizenship Tax Planning; (3) Expatriation Tax Planning

Expatriation Tax Planning for US Citizens – (1) “Covered Expatriate” Avoidance Planning; (2) Capital Gains Tax Planning; (3) Special Inheritance Tax Planning

Departure Tax Planning for Relinquishment of “Green Cards” – (1) “Long-Term Residence” Avoidance; (2) “Covered Expatriate” Avoidance Planning; (3) Planning for Capital Gains and Other Tax Recognition; (4) Special Inheritance Tax Planning

Relocating to Puerto Rico to Slash Taxes Without Relinquishing Your US Citizenship or Greencard - "(1) "Bona Fide Residence" Test; (2) "Presence" Test; (3) PR Act 60 Grant Qualification; (4) PR Tax Planning for Global Business Operations

Delinquent FBAR Reports and Other Foreign Asset and Information Reporting - (1) US Foreign Income and Asset Reporting: (2) Correcting Failures to File Reports; (3) IRS Tax Compliance Programs for Penalty Abatement

US Estate Tax, Gift Tax and Other Transfer Tax Planning – (1) Estate Tax Planning; (2) Gift Tax Planning; (3) Generation-Skipping Transfer Tax Planning; (4) Special Inheritance Tax Planning for Expatriates

Federal Income Tax Audits and Appeals – (1) Tax Audit Management; (2) Response to Notice of Proposed Assessment; (3) Appeals to Independent Office of Appeals

Feel free to call us at (760) 578-5093, contact us via email at Brent@LanceCrossborder.com or by using our online contact form. We will respond to all relevant inquiries without any obligation.