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Peter Rehm focuses his practice on international tax and tax controversy matters. He draws from his time at major accounting firms to assist corporations, partnerships, trusts, estates, and individuals with resolving their tax noncompliance issues through the various voluntary disclosure programs offered by the IRS, such as the Late Filing Waiver Procedures (LFWP), the Streamlined Foreign Offshore Procedures (SFOP), the Streamlined Domestic Offshore Procedures (SDOP), the Delinquent International Information Return Submission Procedures (DIIRSP), and the Delinquent Withholding Tax Procedures (DWTP), among others. 

Peter also has extensive experience in tax controversy. He has handled all stages of the tax defense and resolution process, including refund claims, audits, appeals, litigation, and disputes various penalties imposed by the IRS, such as international information return penalties (e.g., Form 3520, Form 3520-A, Form 5472, and Form 5471) and others.

Further, Peter has experience in inbound and outbound international tax transactions and various complex compliance and reporting issues, including individual and corporate foreign tax credits, income inclusions, entity classifications, foreign trust characterization, the Foreign Investment in Real Property Tax Act (FIRPTA), Passive Foreign Investment Companies (PFIC), Tax Treaties, the Foreign Account Tax Compliance Act (FATCA), withholding taxes, information reporting, and the preparation of Private Letter Rulings (PLRs). 

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