Tax Regularization & Tax Controversy
Securing the past. Controlling the present. Protecting the future
In an era of enhanced global tax transparency, tax authorities now have extensive tools to identify undisclosed offshore assets.
Through the Common Reporting Standard (CRS) and automatic exchange of information, authorities can access data relating to foreign bank accounts, financial assets and offshore structures, significantly increasing exposure to tax risk.
In this environment, delayed or poorly managed action may result in substantial tax reassessments, penalties, and, in some cases, criminal exposure.
Our firm provides strategic, technical, and highly confidential support in both tax regularization and tax controversy matters.
Our Approach
Our practice focuses on two key dimensions:
Our Services
Voluntary disclosure & regularization of offshore assets
- undisclosed offshore bank accounts
- international investment portfolios
- interests in foreign entities
- trusts, foundations and fiduciary structures
- foreign real estate holdings
Tax audits and investigations
- assistance during personal tax audits (ESFP)
- responding to requests for information on offshore assets
- structuring technical responses and supporting documentation
- negotiating proposed tax adjustments
Case Studies
Regularization of undisclosed offshore bank accounts
Regularization and voluntary disclosure of financial assets in Latin America.
View case details Hide details
A client holding bank accounts in Latin America that were not declared in France seeks to regularise their tax position. We reconstruct financial flows, prepare amended tax returns and handle interactions with the tax authorities.
Key Contributions:
- reconstruction of international financial flows
- preparation of amended tax returns
- handling negotiations with tax authorities for penalty reduction
Tax audit on cross-border income
Defense and response preparation for tax audits regarding foreign-source income.
View case details Hide details
A taxpayer is subject to a tax audit regarding income received from foreign sources. We structure the response, substantiate the financial flows, and negotiate the proposed tax adjustments.
Key Contributions:
- structuring technical and evidence-based defense
- documented substantiation of cross-border flows
- negotiation of proposed adjustments to minimize tax liability
Have questions about this area?
Describe your situation briefly. Our team will get back to you with a clear initial guidance.
Building your next step together.
Tell us about your project, and we will contact you to schedule a meeting and answer your questions.