Ajay Whittemore's practice focuses on international tax planning and controversies. In the planning area, Mr. Whittemore advises clients regarding both inbound and outbound matters, including tax treaty analysis, transfer pricing, tax deferral opportunities, and the architecture and implementation of tax-efficient business structures. He also advises private clients regarding pre-immigration planning, expatriation issues, foreign trust issues, investment in U.S. businesses and real estate, and global succession planning.
Mr. Whittemore has experience advising concerning the tax treatment of cryptocurrency transactions (such as Bitcoin, Ethereum, etc.), as well as handling related compliance issues vis-à-vis the IRS.
In the area of tax controversies, Mr. Whittemore represents clients at all stages of IRS disputes. He has extensive experience in advising clients regarding the IRS’s Offshore Voluntary Disclosure Program, as well as alternative approaches for achieving compliance with respect to foreign accounts. He also handles audits and investigations of undeclared foreign accounts. Mr. Whittemore provides compliance advice regarding interests in foreign trusts and business entities, as well as foreign pension reporting.
Mr. Whittemore joins Rimon from Sharp Partners P.A. Previous to that, Mr. Whittemore served for three years as a prosecutor with the State Attorney’s Office for the Nineteenth Judicial Circuit of Florida.
- “Arbitrary and Capricious? An Update on FBAR Enforcement post-Colliot,” CalCPA San Francisco ITAX, February 28, 2019.
- “IRS and DOJ enforcement of cross-border tax compliance in 2018,” CalCPA East Bay ITAX, November 13, 2018.
- "Goodbye and Good Riddance? Section 877A and the Hazards of Ending US Tax Residency,” CalCPA San Francisco ITAX, June 22, 2017.
- “The Essentials of Pre-Immigration Planning,” City National Bank, May 16, 2017.
- “Green Cards and Expatriation: The Immigration, Tax Planning and Tax Compliance Aspects,” STEP Mid-Atlantic Chapter, November 12, 2015.
- "Tax Planning & Compliance for EB-5: Planning and Implications for Immigrating to the U.S.,” IIUSA 4th Annual EB-5 Market Exchange, October 24, 2014.
- AV Preeminent, Martindale-Hubbell (Internet Brands), 2020
- American Bar Association, Tax Section
- Tax Section of the California Bar
- Tax Section of the Florida Bar
"What Happens in China Stays in China: U.S. Tax Traps for Immigrant Investors” Tax Notes International 2013
News, Events, & Insights
Rimon Opens Shenzhen Office
News January 24, 2019
International Tax Attorney, Ajay Whittemore, joins Rimon as Partner in its San Francisco office
News October 25, 2017