Handling the toughest tax cases and the most sophisticated estate tax plans

PHILOSOPHY OF THE PRACTICE & EXPERIENCE

Over the past 38 years, Richard S. Lehman has established a sophisticated private practice focusing on tax law. His background, education, and experience has distinguished him in this complex field. A published author and noted speaker,
Mr. Lehman has carved a reputation as a powerful client advocate.

He is a graduate of Georgetown Law School with a Master’s of tax law from New York University Law School. He has served as a law clerk to the Honorable William M. Fay, U.S. Tax Court and as Senior Attorney of the Interpretative Division in the Chief Counsel’s Office of the Internal Revenue Service in Washington D.C., the IRS’s internal law firm.

A one-time partner in one of the nation’s largest law firms, Mr. Lehman has found that practicing on his own matches his client’s entrepreneurial spirit.

Central to Mr. Lehman’s practice is recognizing that legal needs do not exist in a vacuum. Numerous legal disciplines often come into play in resolving matters. Consequently, Mr. Lehman is regularly approached to untangle complex legal and tax situations that require the expertise of numerous lawyers in varied disciplines.

Mr. Lehman has a broad network of contacts in the legal profession on every continent. Regardless, of the issue, he has consistently guided clients through the legal maze with sophisticated tax strategies that assist a wide range of clients including:

Those with complex tax dilemmas, both domestic and foreign
Foreigners investing in and immigrating to the United States
United States citizens and corporations investing in foreign countries
Families with complicated estate tax situations
Ponzi scheme victims seeking tax relief

The FATCA Takes A Team; The role of Lawyer and Accountant

United States taxpayers, which include United States citizens, Green Card holders and alien individuals who are considered to be United States residents for U.S. tax purposes, who have interests in and/or control over unreported foreign bank accounts are waking up to the fact that not only are they responsible for reporting the existence of these foreign bank accounts as part of their United States tax returns, but also the fact that they may be subject to small or large penalties if they have not reported the existence of these accounts as part of their United States tax returns.

The IRS has established three separate programs under which the American taxpayer can now report foreign bank deposits that have been unreported in the past. Read this full article

The IRS Streamlined Filing Compliance Procedures explained by Richard S. Lehman

The new I.R.S. changes to Offshore Bank And Foreign Asset Disclosure Programs is explained by United States Tax Attorney, Richard S. Lehman

This is an extremely important and valuable I.R.S. Program. It allows almost every American who has been afraid to step forward and disclose their foreign assets to the U.S. taxing authorities to do so with minimized penalties on unpaid taxes and unfiled information returns.

Purpose of the streamlined procedures: The streamlined filing compliance procedures are available to taxpayers certifying that their failure to report foreign financial assets and pay all tax due in respect of those assets did not result from willful conduct on their part. Read full article here.

The Tax Wake Up Call For Americans With Unreported Assets And/Or Income

Web Seminar Topics: I.R.S Grants NEW Amnesty Program beginning taxable year 2012. Plus two pieces of tax legislation that have been phased in over the last few years;

Beginning Taxable Year 2011, The Foreign Account Tax Compliance Act (FATCA)
Beginning in 2013, Foreign Financial Institutions (FFI’s) Report On Americans.

This was not the years of a Do Nothing Congress. Those two new pieces of legislation, together with existing law, now make sure that every U.S. taxpayer’s assets and source of income, both foreign and domestic, will be included in an information return or a tax return that must be filed with the internal revenue service of the united states. Learn more, watch this free on-demand seminar..

PONZI SCHEME TAX LOSS – RECOVERY AND TAX REFUNDS

ARTICLE: Taxation of the Clawback in a Ponzi Scheme
Because these clawbacks are granted under two separate principals of law, the lost amount of profits and principal must be carefully defined and properly claimed as a deduction or confusion will reign with the IRS. Read this full article

Background Reports

This is a series of reports focusing on the tax benefits available as a result of Ponzi Scheme losses. These Reports are not intended to be and cannot serve as legal advice to any reader. Each taxpayer has their own unique factual situation which is going to need to be reviewed by tax advisors and litigation counsel before any legal conclusions can be reached.

Report No. 1: The Basics: Download as pdf
Report No. 2: A reasonable prospect of recovery: Download as pdf
Report No. 3: Is the Safe Harbor Worth it? Download as pdf

Web Seminar-This is for victims and financial professionals. Learn how recovery of “Tax Refunds” is quick and reliable. How to best secure a tax refund from Ponzi Scheme losses, how the government has made recovery easier and what you need to know about theft losses, How to plan and implement tax refund requests for Ponzi Scheme tax losses for maximum benefits now, and in the future.

UNITED STATES TAXATION OF FOREIGN INVESTORS

Web Seminar - U.S. Taxation (General Overview) The following seminar is intended to provide the foreign investor both corporate and individual, with a basic introduction to the tax laws of the United States as they apply to that foreign investor. Click here to read article and watch video presentation.

ARTICLE: United States Taxation of Foreign Investors
This article is available in 8 languages: English, French, Spanish, German, Italian, Chinese, Arabic, Russian. Click here to pick preferred language.

PRE IMMIGRATION INCOME TAX PLANNING

Web Seminar - Pre-Immigration Tax Planning.

The immigrating Non Resident Alien must prepare for a tax life as a Resident Alien. This means closing out the past and taking advantage of all of the tax deductions and tax investment incentives offered by the U.S. Tax Code. It may mean leaving certain of the taxpayer’s foreign investments in place.

Often immigrating residents are unfamiliar with the tax laws of the United States, that they will face upon obtaining their resident status. Often this lack of knowledge can be costly with immigrants paying unnecessary taxes and burdening themselves with liabilities.
Click here to watch web seminar and read full article

FOREIGN INVESTORS IN U.S. REAL ESTATE

Web Seminar - Investing in U.S. Real Estate.

This Web seminar explains the tax laws governing real estate investments in the U.S. and the techniques available to reduce U.S. taxes on real estate profits earned by Foreign Investors. There is an emphasis on tax planning for the non-resident alien individual and foreign corporate investor that is planning to invest in United States real estate.

Watch an Advanced video on Foreign Investors in United States Real Estate.

ARTICLE: Tax Planning for Foreign Investors Acquiring United States Real Estate Investments

These articles are available in 8 languages included: Portuguese, Chinese, Deutsch, Francais, Italiano, Russian, Espanola

Investments of $500,000 and under
(English read now)
Investments of One Million Dollars and over
(English read now)

UNITED STATES TAX BENEFITS FOR EXPORTING

Web Seminar : The United States – Major Tax Reductions for Export Profits

With all profits hard to come by, U.S. taxpayers that sell, lease or license “export property” which is manufactured, produced or grown in the United States (not more than 50% of which attributable to U.S. imports); can take advantage of tax support for their export profits in the Internal Revenue Code. Export profits can be taxed at a 15% tax rate instead of the 35% tax rate on ordinary income (and sometimes 50% tax rates when state and city taxes apply).Click here to watch web seminar and read Article

ARTICLE: The Export Disc Corporation - Computer Software and Internet Sales and Licenses
Click here to read Article