Eileen, who is Of Counsel to the Firm, presently focuses her practice on the due diligence and compliance obligations arising under the U.S. Foreign Account Tax Compliance Act (FATCA) and the Common Reporting Standard (CRS). Eileen assists with the preparation and filing of IRS Form 8966 (FATCA Report) for entities classified as investment entity foreign financial institutions (FFIs) and direct reporting non-financial foreign entities (NFFEs) to report to the IRS on certain U.S. owners. She also assists with the preparation and filing of CRS reports for investment entity financial institutions (FIs) to report to their local authorities on certain individuals that are tax resident in CRS reportable jurisdictions. Eileen likewise concentrates on other compliance matters, such as FATCA registrations and sponsoring entity arrangements; preparation of IRS W-8 forms and CRS self-certifications; preparation of FATCA and CRS written policies and procedures for entities; review of subscription agreements, which now include FATCA and CRS due diligence; and preparation of IRS Form 8938 and FinCEN Form 114, Foreign Bank Account Report (FBAR) for U.S. persons to self-report specified foreign financial assets.
In addition, Eileen assists in coordinating annual filings affecting foreign trusts, such as IRS Form 3520-A (Annual Information Return of Foreign Trust with a U.S. Owner), Foreign Grantor Trust Owner Statements, and Beneficiary Statements for foreign trusts that made distributions to U.S. beneficiaries; IRS Form 5472 for foreign-owned U.S. LLCs to report transactions with their foreign owners and related parties; and the FBAR for U.S. trustees, grantors and/or beneficiaries of foreign trusts formed under U.S. law to report financial interests in or signature authority over foreign financial accounts held by the trusts or their holding companies.
Eileen previously practiced in the area of estates and trusts for many years. She has extensive experience advising high net worth U.S. individuals and families regarding all aspects of their estate and tax planning, including the design and preparation of highly personalized estate planning instruments and the implementation of a wide array of wealth transfer techniques. She has handled the administration of numerous complex estates and trusts, including advising individual and corporate fiduciaries as well as beneficiaries regarding the diverse tax and non-tax issues that arise in the course of administration, the preparation and audit of estate, gift and GST tax returns, and the preparation and settlement, both judicially and non-judicially, of fiduciary accounts. Eileen has assisted not-for-profit organizations in their formation, operation, and dissolution.