As a retired International Tax Partner at a Big Four accounting firm, my experience has covered working with foreign companies and individuals investing in the US, as well as US companies creating global structures for their international operations. In addition, I am now working with high net worth families in developing a global tax efficient plan particularly with the US resident members of the family. Working in acquisition and disposition of US real estate investments by foreign persons is also included. Finally, I have worked to resolve a number of conflicts between taxpayers and the IRS as well as to obtain favorable Advance Pricing Agreements with the IRS, and settle failure to file penalty claims by the IRS.