Tom Neff, CPA, is the Firm President and Co-Chair of RINA’s International Tax Practice Group. Tom advises family offices investing abroad, foreigners moving to the U.S. or investing in U.S. real estate, Americans moving internationally, and entrepreneurs from other countries establishing a business in the U.S. Tom assists outbound U.S. businesses in structuring overseas operations in a tax-efficient manner and he assists inbound businesses with U.S. entity formation. These advisory services include reviewing the tax treaties to determine how to efficiently structure intercompany transfer of funds and mergers and acquisitions.
Tom’s areas of expertise include:
- Foreign activities of U.S. taxpayers including the use of DISCs;
- Foreign tax credit utilization;
- Choice of entity planning including foreign joint ventures, dual-status entities, and foreign branches;
- Controlled Foreign Corporations (CFC);
- Passive Foreign Investment Company (PFIC) compliance and planning;
- Transfer pricing;
- Structuring for acquisition, operation and disposition of U.S. real estate;
- U.S. beneficiaries of foreign trusts; and
- Gift, trust and estate considerations for non-citizens with U.S. based assets.
Tom earned a Bachelor of Science degree from the University of Dayton, OH in 1986. Tom joined RINA in 2002 and his background includes nine years with a large Wall Street law firm and 5 years with a CPA firm in New York and the Virgin Islands prior to relocating to San Francisco. Tom enjoys hiking the Oakland Hills, taking his dog to the beach, attending live rock music concerts and performing monthly with an improv troupe call Butter Boots at the All Out Comedy Theater in Oakland.
- International Tax
- Transfer Pricing Studies
- Corporate and Multi-State Tax & Consulting
- Real Estate Partnerships
- Professional Services
- Manufacturers & Distributors