Tax Planning for Businesses and Individuals
Mr. DiRuzzo provides comprehensive income tax planning for individuals and businesses. Mr. DiRuzzo's clients range from private individuals and small businesses to large Fortune 100 companies and national accounting firms. Mr. DiRuzzo often advises on the structuring of transactions, but also reviews the transaction documentation with a view to minimizing the risk in the event that there is an audit (including drafting disclosure statements on tax returns to minimize the risk that penalties will be asserted). Mr. DiRuzzo also advises his clients on the reporting requirements that occur when international transactions and structures are involved, such as controlled foreign corporations ("CFCs"), passive foreign investment companies ("PFICs") and transfer pricing.
In respect to partnerships and limited liability companies ("LLCs"), Mr. DiRuzzo assists in the drafting the partnership/LLC formation document and operating agreement to ensure that the entity does not fall within the scope of the unified audit provisions of the Internal Revenue Code (i.e., TEFRA and BBA).
For those considering becoming United States permanent residents ("green card holders") or United States citizens, Mr. DiRuzzo works with his clients to minimize the effects of becoming a "United States person" (both in the amount of tax that will have to be paid and the reporting obligations under the Internal Revenue Code and the Bank Secrecy Act).
Mr. DiRuzzo also advises his clients on United States Virgin Islands issues regarding Virgin Islands sourced income and effectively connected income. Structuring of both in-bound and out-bound (to the 50 States) USVI transactions requires the ability to view a transaction from both an US and an USVI perspective including the application of the "Mirror Code." Mr. DiRuzzo also obtains Tax Payment Agreements from the Virgin Island Bureau of Internal Revenue, which allows entities to minimize, or even eliminate, the filing obligations and related tax liabilities of its shareholders, partners, or members under Section 932(a) of the Internal Revenue Code.