[Fredslist] FW: Request for Legal Advice

[Langsam, Andrew]

-----Original Message-----
From: Langsam, Andrew 
Sent: Monday, June 22, 2009 7:22 AM
To: Langsam, Andrew
Subject: Request for Legal Advice


I have a client with funds in an overseas (Swiss) account for likely 20
years.  He wants to look into either repatriating the funds (paying
taxes, interest, penalties on the  undeclared US income) or transferring
to another account (either US or foreign).  We are gathering facts,
e.g., original amount ;  source of funds (none of the money is from
anything like drugs, nor sales of contraband), income over the years,
etc.  Indeed the client says that the original amount of the deposit is
from the legitimate sale of a factory in Italy.  The client  just
inherited the account from the original depositor so there may be some
potential discussions about penalties with the IRS.  
 
I am looking for a lawyer who is knowledgeable about repatriation and
with negotiations with the IRS.  Any suggestions?
 
Andy Langsam 
ALangsam at pryorcashman.com 


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