PLAN YOUR
GLOBAL ADVANTAGE.

Sophisticated International Tax Structuring, Cross-Border M&A, and Regulatory Consulting. Leveraging deep insight to optimize global operations and preempt controversy.

Strategic Planning Our Expertise

PRECISION IN
COMPLEXITY

Effective global tax planning requires more than just knowing the rules—it requires knowing how they were written.

Deepan Patel leverages high-level experience from Nelson Mullins (Of Counsel) and PwC's Washington National Tax practice to structure tax-efficient cross-border transactions for multinationals and high-net-worth investors.

This advisory capability is uniquely fortified by his tenure at the IRS Office of Chief Counsel, where he drafted key Treasury Regulations. We don't just defend against audits; we architect operations to withstand them.

Admissions

  • Florida Bar
  • Washington D.C. Bar
  • United States Tax Court

Education

  • FSU College of Law (Honors)
  • University of Oxford (Intl. Trade)

Global Structuring

Inbound/Outbound planning, entity classification, and repatriation strategies (GILTI/FDII).

Mergers & Acquisitions

Tax-efficient deal structuring, due diligence, and post-transaction integration.

Financial Products

Complex instrument analysis, hedging, and crypto-asset reporting under Chief Counsel guidance.

Tax Controversy

Strategic defense for audits, 3520 penalties, and U.S. Tax Court litigation.

Capabilities

STRATEGIC SOLUTIONS

Corporate Structuring

Optimizing entity selection and jurisdiction for tax efficiency. We handle Subpart F, GILTI, and BEAT analysis for US-based multinationals and foreign investors entering the US market.

Consult on Structure

Cross-Border Transactions

Advising on tax-free reorganizations, liquidations, and intercompany financing. We structure Real Estate Funds (REITs/FIRPTA) and IP migration strategies to minimize leakage.

Transaction Advisory

Regulatory Defense

Effective global tax planning requires more than just knowing the rules. It requires knowing why and how the rules were written.

Secure Defense

Representative Matters

Cross-Border Mergers

Structured multi-jurisdictional acquisition

Streamlined Filing & Amnesty

Non-willful offshore certification

Inbound Real Estate

Fund structuring for foreign capital

L-1 Visa Planning

Pre-immigration asset protection

Common Questions

FREQUENT INQUIRIES

How do I repatriate foreign profits efficiently?

Repatriation strategies have evolved significantly post-TCJA. We analyze your Dividends-Received Deduction (DRD) eligibility and Foreign Tax Credit (FTC) buckets to minimize withholding and residual U.S. tax upon bringing cash back to the U.S.

I haven't filed US taxes in years. Am I in trouble?

U.S. citizens living abroad ("Accidental Americans") can often use the Streamlined Foreign Offshore Procedures to come into compliance without facing criminal liability or the 5% penalty, provided the conduct was non-willful. Immediate action is recommended before the IRS contacts you.

What triggers an automatic 25% penalty on Form 3520?

Late filing of Form 3520 (reporting foreign gifts or trusts) triggers a systemic penalty of up to 25% of the gross value of the asset. This is often automated by the IRS computer system. We fight these penalties at Appeals.

Does the IRS track Cryptocurrency?

Yes. The IRS uses "John Doe" summonses on exchanges. Receiving Letter 6173 or 6174 means they likely have information on your trading activity. We handle both the reporting and the defense.

What are the new Beneficial Ownership (BOI) rules?

Under the Corporate Transparency Act, reporting companies (including foreign entities registered in the US) must disclose beneficial owners to FinCEN. We manage this ongoing compliance to avoid civil penalties.

Latest Intelligence

INSIGHTS & ANALYSIS

The Ultimate Guide to IRS Form 3520 Penalties

FEB 2026

A comprehensive strategy for abating the automatic 25% penalty on foreign gifts and inheritances.

Read Analysis

Pre-Immigration Tax Planning Checklist

JAN 2026

Essential steps for HNW individuals to mitigate U.S. tax exposure before becoming residents.

Read Analysis

Corporate Transparency Act for Foreign Owners

DEC 2025

Understanding "Substantial Control" and reporting obligations for international investors.

Read Analysis

Inside the IRS Appeals Process

NOV 2025

A former Appeals Officer's perspective on how settlements are actually reached.

Read Analysis

PRIVILEGED CONSULTATION

To discuss your legal needs, please contact our office.