International Taxation Services

Practice Area
We are U.S. tax lawyers. Our practice is concentrated on individuals, businesses and transactions with an international element. Our clients are mostly individuals, families and closely held businesses but, because of our background in large firms, we occasionally represent large companies in areas within our specialized field of experience and knowledge.

We provide carefully tailored charitable tax planning services to manage the impact of a substantial liquidity event such as the sale of a business or highly appreciated real estate. We understand a desire to benefit both family and charity, and we advise our clients on the tools and approaches to make a meaningful impact and work together as a family to share their passion and vision and to supplement and strengthen family governance. We help our clients form their own private family foundations and avoid violating any of the myriad of IRS rules about how to run a foundation and what tax compliance rules must be observed.

Many of our clients want to further their foundation’s charitable mission by engaging in program related investing and mission related investing, including micro-loans and similar strategies, or directly carrying out charitable projects. We guide them in these activities.

We also form and counsel nonprofit public charities, advising on strategy and fundraising, providing board training and working closely with development staff to bring gifts to fruition.

We regularly work on international charitable matters involving U.S. nonprofits operating or fundraising abroad, the U.S. operations of foreign charities, and “American Friends of” organizations making grants outside the United States. Jane Peebles is an established expert in cross-border philanthropy.

We assist corporations with structuring and implementing corporate philanthropy programs.

We regularly advise on and document a broad array of charitable gifts including:

The attorneys at Karlin & Peebles are not only experts in the law, they also bring proven judgment and perspective to each case. They invest time in understanding our clients’ individual objectives and creatively and carefully tailoring solutions to achieve them. Our lawyers have over 50 years of combined experience providing estate planning services, and Partner Jane Peebles is a Southern California Super Lawyer in the field of Estate Planning.

Our Clients

We represent high net-worth individuals and families, and in addition to this core client base, we also represent a number of entrepreneurs. We frequently represent clients facing complex or novel situations and those who can benefit from the sophisticated planning techniques we employ. We do not impose a minimum net-worth requirement, preferring to serve a range of clients whose needs vary at different stages of life.

We help our clients develop their thoughts on how and when to transfer wealth to children and grandchildren. Because of the rapid increase in many of our clients’ net worth, this transfer issue has become especially acute in recent years. Besides drafting trusts with terms appropriate for limiting and protecting the flow of wealth to children, we work with families to involve the children in family philanthropy.

Our Services

In addition to fundamental estate planning techniques, we have considerable background and experience in the following areas:

  • “Estate freezing” techniques such as Grantor Retained Annuity Trusts (GRATs), Qualified Personal Residence Trusts (QPRTs) and installment sales to “defective” grantor trusts
  • Asset value discounting techniques such as fractional interest discounts and discounts generated through use of limited liability companies (LLCs) and family partnerships (FLPs)
  • Business succession planning, including buy-sell agreements
  • Planning for a move to another state or country
  • International estate planning
  • Planning for distributions of retirement benefits
  • Planning for stock options
  • Community property planning
  • Asset protection planning through use of U.S. and offshore vehicles
  • Planning for same sex couples and other nontraditional families
  • Forming and advising exempt organizations and family charitable foundations
  • Acting as co-counsel with other lawyers to handle international planning matters

Our Clients’ Integrated Team

We work with our clients’ accountants, investment advisors, foreign counsel and other members of their professional team to provide coordinated planning to minimize estate, gift and income taxation while meeting personal planning objectives.

We are planners, first and foremost, and we implement the planning we recommend.  But we also assist our clients with tax compliance, working closely with their accountants, and with tax controversies, often in collaboration with specialist tax controversy counsel.

Modern tax systems are complex and dynamic. The interaction of the tax and legal systems of different countries can multiply the complexity. Complexity and change create uncertainty. Uncertainty creates risk, because there can rarely be complete certainty about the interpretation of tax law or its implementation by tax administrators.

As planners, we try to be creative and flexible, but we are at heart conservative. Our aim is for our clients to have a high degree of confidence in our planning, with a proper understanding of the risk, because risk can be managed and mitigated but can rarely be eliminated.

Our international tax practice covers a wide range of topics and we have advised individuals and businesses active in many industries, including manufacturing, technology, services, real estate, investment, and entertainment. We regularly cooperate with an extensive network of advisors in many disciplines and in many countries and our ability to be effective is enhanced by our extensive foreign language capabilities:

Planning for individuals who move to the United States from another country or move to another country from the United States

Tax and estate planning for multinational families, where individual family members visit or reside in the United States and others reside abroad

Planning for foreign investment in the United States

Planning for outbound investment from the United States

Cross-Border Philanthropy

Compliance and Controversies

Contact Us

Contact Us Today

If you require assistance within one of our specialized practice areas or would like to inquire about our services, we invite you to contact our firm.