Silver & Co., U.S. Tax Attorneys

U.S. Tax Lawyers for US/Non-US Persons - Formerly with IRS Estate & Gift Tax Unit & U.S. Tax Court

Silver & Co., U.S. Tax Attorneys

10 Abba Even Street
Herzliya Pituach 4724044
Israel

Phone+972 (9) 972-6000
Fax +972 (9) 972-6001

Website www.silvercolaw.com
Contact Silver & Co., U.S. Tax Attorneys Contact the Law Firm

Law Firm Overview

Silver & Co. is located in Herzlia Pituach, Israel and provides U.S. tax and/or estate planning for U.S. and non-U.S. individuals and entities around the world. Practice areas consist of U.S. income and capital gains tax matters, estate and gift planning, expatriation (citizenship and LTR) exit tax and related penalties, FBAR/FATCA and related PFIC and pension issues, and advisory services for wealth management.

Monte Silver has more than 20 years of international tax experience, including work at the I.R.S. and U.S. Tax Court as well as numerous state-level revenue agencies. He is admitted to the California and Israel Bars and admitted to practice before the U.S. Tax Court.

Mr. Silver creates and implements innovative, cost effective, end-to-end strategies that address U.S. and non-U.S. local tax laws and related matters.


Areas of Law





Areas of Law Description

To US Persons

Full spectrum of U.S. income and capital gains tax matters, taking into account issues such as:

Foreign entities & CFC related matters
- Marital status and related matters
- IRC 911
- Relevant Tax Treaties
- US Social Security liability

Estate and gift planning
- Residency and domicile​
- Spousal status and related matters

Expatriation (citizens and LTR), exit tax and related penalties
- IRC sections such as 877A, 2104 and 2801

FBAR/FATCA and related PFIC and pension issues

Advisory services for wealth management, including generational planning, trusts and philanthropy.


Non-U.S. Persons and Entities

Federal and state income and capital gains tax as is related to:
- Investment in U.S. real estate (FIRPTA).
- U.S. business activity of foreign companies/partners, taking into account issues of PE, ECI & Tax Treaties.
- Non-U.S. partners of businesses with U.S. presence. ​
- Relocation issues into or out of the U.S.

Advanced estate/gift tax solutions for: ​
- Existing and prospective investments in U.S. real estate and other US situs assets.
non-U.S. partners of business with U.S. ECI.
- Generational transitions and strategies.
- Sudden death and Form 706 planning and opinions.

Pre-Immigration/relocation tax planning.

Advisory services for wealth management, including generational planning, trusts and philanthropy.


We offer innovative, cost effective and end to end solutions addressing U.S. and non-U.S. local law.




Partners

Monte Silver Mr. Monte Silver
Partner in Charge
Estate and Trust, Inheritance Law, International Investments, Probate, Tax Planning

  

More Information on Silver & Co., U.S. Tax Attorneys

Firm
Bio
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Articles

Articles Published by Silver & Co., U.S. Tax Attorneys

 Off-Shore Accounts: The Panama Fiasco

The disclosure of 11.5 million documents held in strict confidence by a Panama law firm displays once again how vulnerable holders of off-shore accounts are. Confidentiality has always stood at the center of offshore financial centers. With an estimated 32 TRILLION dollars held ‘offshore’, the US and other countries looked for ways to get their hands on their share.

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 To Give Up or Not Give Up a U.S. Citizenship for Tax Purposes? That Is the Question

Many U.S. citizens or green card holders, seeking to avoid the long and heavy arm of Uncle Sam, visit their tax attorney and the first sentence they say is "I want to give up my citizenship/green card". For many reasons, few in fact do so, as other solutions exist. The purpose of this article is to explain the tax consequences of such expatriation.

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 Pre-Immigration Tax Planning for Moving to the U.S.

A person who is neither a United States citizen nor resident can take certain actions that significantly impact the exposure to U.S. tax. Nowhere is the impact as significant as the decision to become a U.S. resident for tax purposes.

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 U.S. Tax Court Ruling Limits Foreign Earned Income Exclusion

Many US citizens and residents living overseas take advantage of up to approximately $100,000 a year in foreign earned income exclusion ("FEIE"). However, entitlement to FEIE is not automatic as the U.S. Tax Court recently ruled.

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 U.S. Tax Court Resolves Long-Outstanding Tax Issue: Is the U.S. Tax Citizen Living Abroad Subject to Capital Gains?

For decades it has been unclear whether a U.S. citizen or green card holder ("U.S. Person") who resides abroad and who sells stock for a gain is subject to U.S. capital gains tax. In May 2016, the U.S. tax court resolved the issue. This issue is relevant to U.S. Persons living abroad, including those who are employees exercising stock options.

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 U.S. Tax System: FATCA. FBAR. PFIC. Trump, Give Us a Break!!

Few are the examples where the multi-level complexity of the U.S. tax system can be seen as is the case with the regulation and taxation relating to foreign financial accounts held in foreign financial institutions by U.S. Persons. From the U.S. perspective, identical or effectively identical terms have completely different meanings and implications, whether we are looking at the FATCA, FBAR or PFIC regimes.

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 Advanced U.S. Estate and Tax Issues for Non-U.S. Persons

The U.S. estate tax and U.S. gift tax are similar but not identical taxes. The estate tax is a tax on what a person owns at death (the estate). The tax is paid by the estate after death. The gift tax is imposed on all gifts of property made during a person’s life. In principle, the gift tax applies to transfers of property that would otherwise have been part of the estate and subject to estate tax at death.

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 U.S. Tax Court Monumental Ruling Will Impact Foreigners with U.S. Businesses or Investments

A precedent-setting ruling recently issued by the U.S. Tax Court changes the way foreigners are taxed in the United States. The ruling states that a foreigner involved in business or investment activity in the United States through a partnership can sell its share of the partnership without paying U.S. capital gains tax, with a special exception for cases where the partnership in involved in real estate activity in the United States (FIRPTA).

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