IRS Audits of Expatriates: Section 965 Transition Tax, Exit Tax, Non-Filers, and the Examination Process

Mr. Parmegiani has considerable expertise in a broad range of tax specialty areas, including the hospitality and real estate industries, both domestic and international business investments, sales and use tax, C Corporations, S Corporations, Partnerships, LLCs and REITs, and state and local tax issues. He has worked extensively with high net worth individuals, including United States taxpayers living abroad and foreign nationals living in the United States and advises foreign groups in establishing domestic business operations. He has spent most of his career with Big Four and other large accounting firm networks, and was also Director of Tax for the New York office of another network for eight years. He frequently contributes tax articles to the PKF International Tax Alert and presents at the annual PKF International Tax Conference.

Ms. Belyavskaya has 15 years of experience working with multinational businesses and high-net-worth individuals. She provides tax compliance and advisory services on cross-border transactions, corporate international restructuring, U.S. entity formation and dissolution issues, as well as global mobility matters and expatriate tax assistance. Ms. Belyavskaya has worked with numerous clients and PKF colleagues around the world on transfer pricing issues and U.S. nexus tax regulations. She has prepared numerous memoranda regarding U.S. tax implications for foreign clients, and she is a contributor to the Firm’s Thought Leadership series. Currently, Ms. Belyavskaya is spearheading the Firm’s efforts to grow its client base in the Commonwealth of Independent States (CIS) in Eastern European and Asian countries. 

Mr. Migliaccio is a Partner in the international tax practice. Prior to joining PKF O’Connor Davies, he worked at two “Big 4” accounting firms in their international tax practices. Mr. Migliaccio has more than 10 years of experience providing consultation on international tax matters, including cross-border transactions, business restructurings and complex compliance issues for multinational corporations, partnerships, private equity funds and high-net-worth individuals. In addition, he regularly leads due diligence and structuring for M&A transactions. As one of the Firm’s most prolific thought leaders, Mr. Migliaccio has written extensively on a wide range of tax topics. He is a co-author of treatise-length discussions on the Base Erosion and Anti-Abuse Tax (BEAT), Passive Foreign Investment Companies (PFICs) and Inversions. Mr. Migliaccio has authored articles for publications such as Law360 and Checkpoint News and has been quoted in Newsday and Bloomberg News. He is also a frequent speaker at industry and tax-related conferences.

Ms. Smith is a partner in the private client and tax team. She focuses her practice on sensitive tax matters, which often involve negotiations with government agencies. Ms. Smith represents clients in a broad range of tax, trust, estate, and business planning issues. Her work involves planning for high net worth US and international families, with particular emphasis on planning for closely-held businesses. Ms. Smith's planning work for clients involves a range of matters, from creating tax-efficient wealth transfer structures to addressing income tax issues arising from investments and operating businesses. She has advised prominent politicians, business people, and well-known athletes. Ms. Smith is known globally as one of the go-to attorneys for individuals with US tax or reporting issues and has represented clients from over 20 countries in the last year. In addition to the traditional tax controversies, such as representing clients in an audit, Ms. Smith has extensive experience in advising clients on issues regarding foreign bank account reporting (FBAR) obligations, the Foreign Account Tax Compliance Act (FATCA), and the Internal Revenue Service's 2009 Offshore Voluntary Disclosure Program, 2011 Offshore Voluntary Disclosure Initiative, 2012 Offshore Voluntary Disclosure Program, 2014 Offshore Voluntary Disclosure Program, Streamlined Filing Procedure and other means of resolving US income and reporting deficiencies. She has represented hundreds of U.S. taxpayers with undisclosed foreign bank accounts.