PHILOSOPHY OF THE PRACTICE & EXPERIENCE
Over the past 38 years, Richard S. Lehman has established a sophisticated private practice focusing on tax law. His background, education, and experience has distinguished him in this complex field. A published author and noted speaker, Mr. Lehman has carved a reputation as a powerful client advocate.
He is a graduate of Georgetown Law School with a Master’s of tax law from New York University Law School and four years of government service as a senior attorney with the Chief Counsel’s Office of the Internal Revenue Service and as a law clerk on the U.S. Tax Court.
Unique to his practice is his position as a sole practitioner. A one-time partner in one of the nation’s largest law firms, Mr. Lehman has found that practicing on his own matches his client’s entrepreneurial spirit.
Central to Mr. Lehman’s practice is recognizing that legal needs do not exist in a vacuum.
Numerous legal disciplines often come into play in resolving matters. Consequently, Mr. Lehman is regularly approached to untangle complex legal and tax situations that require the expertise of numerous lawyers in varied disciplines.
Mr. Lehman has a broad network of contacts in the legal profession on every continent. Regardless, of the issue, he has consistently guided clients through the legal maze with sophisticated tax strategies that assist a wide range of clients including:
1. Those with complex tax dilemmas, both domestic and foreign
2. Foreigners investing in and immigrating to the United States
3. United States citizens and corporations investing in foreign countries
4. Families with complicated estate tax situations
5. Ponzi scheme victims seeking tax relief
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I.R.S. New AMNESTY PROGRAM & I.R.S. REPORTING OF FOREIGN ASSETS BY AMERICANS
The I.R.S. has offered a new Amnesty Program for Taxpayers who have not paid taxes on foreign bank deposits and other foreign assets. It is expensive but insures no criminal charges. Plus, The Foreign Account Tax Compliance Act (FATCA). This seminar also explains the details of a new I.R.S. Information Form 8938 and reporting requirements that force every U.S. taxpayer, (both individuals and entities) to disclose almost all foreign investment assets, including tangible assets, such as art, jewelry and real estate if the tangible assets were not acquired with after tax dollars.
ARTICLE: The Foreign Account Tax Compliance Act (FATCA). Americans now required to disclose all foreign financial assets. ARTICLE: Foreign Bank Deposits and Financial Assets – The Jaws are Closing on the U.S. Taxpayer. PONZI SCHEME TAX LOSS – RECOVERY AND TAX REFUNDS
This web seminar is for victims and financial professionals. Learn how recovery of “Tax Refunds” is quick and reliable. How to best secure a tax refund from Ponzi Scheme losses, how the government has made recovery easier and what you need to know about theft losses, How to plan and implement tax refund requests for Ponzi Scheme tax losses for maximum benefits now, and in the future.
Background Reports This is a series of reports focusing on the tax benefits available as a result of Ponzi Scheme losses. These Reports are not intended to be and cannot serve as legal advice to any reader. Each taxpayer has their own unique factual situation which is going to need to be reviewed by tax advisors and litigation counsel before any legal conclusions can be reached.
ARTICLE: Favorable Tax Consequences – Ponzi Schemes and The Clawback Most of us are familiar with the concept of the Ponzi Scheme. An investment built on phony profits that crashes and burns, financially devastating many. What is less familiar is the fact that an investor in a Ponzi Scheme cannot only lose all of their investment. Investors in Ponzi Schemes can also be forced to pay back additional moneys earned form the Ponzi Scheme years before it exploded. This is what is known as a clawback. ARTICLE: Ponzi Schemes and Theft Losses – What to do if there is NO Safe Harbor? There are many reasons a taxpayer victim of a Ponzi Scheme will either not fit in the Safe Harbor or will be forced to waive valuable tax rights in the event they choose the Safe Harbor. Therefore it makes sense to study how to deal with the I.R.S. if you have a theft loss and you will not or cannot use the Safe Harbor. VIDEO: ‘WEALTH & WISDOM” on PBS Station WXEL: SETTLING WITH THE INTERNAL REVENUE SERVICE (IRS)
CLE Credits for Attorneys |
UNITED STATES TAXATION OF FOREIGN INVESTORS
The following seminar is intended to provide the foreign investor both corporate and individual, with a basic introduction to the tax laws of the United States as they apply to that foreign investor. Click here to view this (on demand) seminar
ARTICLE: United States Taxation of Foreign Investors
PRE IMMIGRATION INCOME TAX PLANNING
The immigrating Non Resident Alien must prepare for a tax life as a Resident Alien. This means closing out the past and taking advantage of all of the tax deductions and tax investment incentives offered by the U.S. Tax Code. It may mean leaving certain of the taxpayer’s foreign investments in place. Often immigrating residents are unfamiliar with the tax laws of the United States, that they will face upon obtaining their resident status. Often this lack of knowledge can be costly with immigrants paying unnecessary taxes and burdening themselves with liabilities.
ARTICLE: Pre Immigration Income Tax Planning. FOREIGN INVESTORS IN U.S. REAL ESTATE
This Web seminar explains the tax laws governing real estate investments in the U.S. and the techniques available to reduce U.S. taxes on real estate profits earned by Foreign Investors. There is an emphasis on tax planning for the non-resident alien individual and foreign corporate investor that is planning to invest in United States real estate.
ARTICLE: Tax Planning for Foreign Investors Acquiring United States Real Estate Investments These articles are available in 8 languages included: Portuguese, Chinese, Deutsch, Francais, Italiano, Russian, Espanola
UNITED STATES TAX BENEFITS FOR EXPORTING
With all profits hard to come by, U.S. taxpayers that sell, lease or license “export property” which is manufactured, produced or grown in the United States (not more than 50% of which attributable to U.S. imports); can take advantage of tax support for their export profits in the Internal Revenue Code. Export profits can be taxed at a 15% tax rate instead of the 35% tax rate on ordinary income (and sometimes 50% tax rates when state and city taxes apply). Click here to view this (on demand) seminar ARTICLE: The United States Tax Benefits of Exporting and The IC-DISC ARTICLE: The Export Disc Corporation – Computer Software and Internet Sales and Licenses
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Web Seminar: The new I.R.S. Amnesty Program for unreported offshore income and deposits.
Making the Offer in Compromise – Offer in Compromise settlements are based upon the Taxpayer’s assets and overall financial situation. The worse the Taxpayer’s financial situation looks, the better the settlement with the I.R.S. The bad economy is one reason why now is the time to consider an Offer in Compromise. 
Web Seminar - U.S. Taxation (General Overview)
Web Seminar – Pre-Immigration Tax Planning.
Web Seminar - Investing in U.S. Real Estate.
Web Seminar : The United States – Major Tax Reductions for Export Profits
