Private Client Services
A custom tax and legal approach
The professionals at Frost Law provide integrated legal, tax, and wealth counsel for high-net-worth individuals, business owners, and globally connected families, all focused on your needs.
What Frost Law’s Private Client Service Can Offer You
Frost Law’s legal and tax professionals offer what few other firms are able to provide.
Dual-Licensed Professionals
A meaningful share of our team is licensed as both attorneys and CPAs, a powerful combination that lets us design tax and legal strategy in a single conversation instead of across two firms and two invoices.
Genuine International Capability
We handle cross-border tax compliance and planning in-house. This includes FBAR, FATCA, Streamlined Procedures, inbound and outbound structuring, and Puerto Rico Act 60.
Controversy Depth Behind Every Position
Frost Law is a tax controversy firm at its core. Every plan we design is built with an eye toward how it would be defended if examined by government regulators, because we know exactly how it would be.
The Common Mistake For High-Net-Worth Individuals: Financial Advice In Isolation.
It’s a common complaint that we hear from new clients frustrated by their previous experiences. The estate attorney doesn’t talk to the wealth manager. The CPA doesn’t talk to the business lawyer. The international tax advisor learns about the new foreign account a year too late. You’re left to be your own general contractor — stitching complex advice together and hoping nothing falls through the cracks. Frost Law’s Private Client Services group is built to be that single, integrated voice looking out for you.
The Clients We’re Built For
High-net-worth and ultra-high-net-worth individuals and families
Business owners contemplating succession, sale, or generational transfer
Executives with concentrated equity, deferred compensation, and complex arrangements
U.S. taxpayers with foreign assets, foreign income, or non-U.S. family members
Non-resident aliens with U.S. investments, U.S. real estate, or U.S.-citizen heirs
Family offices and the principals they serve
Trustees, executors, and fiduciaries needing technical tax and legal support
Charitable organizations, private foundations, and philanthropic families
Meet Your Team
PCS is delivered by a cross-disciplinary team drawn from Frost Law’s tax, business, estates, and international practice groups — coordinated to work as a single unit on client matters.
Our Private Client Services
PCS is organized around the client, not around the internal practice group. Depending on your situation, an engagement may draw on any or all of the following areas of counsel.
Individuals & Families
For individuals and families, Frost Law PCS offers wealth transfer, estate strategy, and personal tax planning.
Frost Law assists with generational estate planning based on your family’s actual goals rather than an off-the-shelf template, including:
- Revocable and irrevocable trust design and drafting
- Lifetime gifting strategies and use of the exemption
- Generation-skipping transfer tax planning
- Different trusts, including GRATs, IDGTs, SLATs, and dynasty trust planning
- Charitable giving, private foundations, and CLATs/CRUTs
- Valuation discount planning
- Multi-year income tax modeling and projections
- State residency and domicile planning
- Prenuptial and postnuptial tax coordination
- Qualified Small Business Stock (Section 1202) planning
- Opportunity Zone strategies
- Retirement account distribution and Roth conversion strategy
Business Owners & Founders
For business owners and founders, we offer succession, transition, and pre-liquidity planning.
We know that every business decision has significant legal, tax, and estate considerations. Frost Law PCS is built so that one professional advisor can answer all of your questions on areas like these:
- Entity selection, restructuring, and reorganization
- S corporation and partnership planning
- Buy-sell and shareholder agreement design
- Owner liquidity and recapitalization strategies
- Pre-transaction tax structuring for exits and sales
- ESOP feasibility and structuring
- Family business governance and succession
- Management equity, phantom stock, and profits interest planning
- Basis management and shareholder basis analysis
- Buy-side and sell-side transaction counsel
- Post-transaction wealth deployment strategy
International & Cross-Border Clients
For international and cross-border clients, we offer Inbound and outbound planning, compliance, and voluntary disclosure.
Your Frost Law private client attorney advisor can help with the legal and tax nuances of foreign-born spouses, foreign-resident children, foreign business interests, and foreign accounts, including:
- Pre-immigration and pre-expatriation planning
- FBAR (FinCEN 114) compliance and controversy
- FATCA and Form 8938 compliance
- Forms 5471, 8865, 3520, and 3520-A reporting
- Puerto Rico Act 60 individual investor and export services planning
- IRS voluntary disclosure representation
- International estate and gift tax planning
- PFIC identification and Section 1291/QEF/mark-to-market elections
- GILTI and Subpart F planning
- Treaty position analysis and dual-residency issues
- Streamlined Filing Compliance Procedures
- Non-resident U.S. real estate investment structuring (FIRPTA)
- Inbound structuring for foreign families investing in the U.S.
Charitable Organizations & Philanthropic Families
For charitable organizations and philanthropic families, we offer structure, compliance, and mission-aligned strategy.
Our private client service is also here to assist with your charitable and philanthropic endeavors, from formation to reporting on issues including:
- Private foundation formation and administration
- Donor-advised fund planning and coordination
- Public charity qualification and Section 501(c)(3) counsel
- Charitable remainder and lead trust design
- Excise tax and self-dealing analysis
- Grant-making structure and program-related investments
- IRS reporting, audit defense, and Form 990 support
- Corporate governance for tax-exempt entities
Fiduciaries, Trustees & Executors
For fiduciaries, trustees, and executors, Frost Law PCS offers fiduciary counsel, tax compliance, and post-mortem strategy.
The private wealth attorneys at Frost Law support individual and corporate fiduciaries at every stage. This is technical and exacting work that must be done right the first time, including areas like these:
- Trustee and executor counseling and representation
- Fiduciary income tax compliance (Form 1041)
- Estate tax return preparation (Form 706) and audit defense
- Post-mortem tax planning and qualified disclaimers
- Trust modifications, decantings, and non-judicial settlements
- Beneficiary distribution planning and disputes
- Trust and estate accounting
- Trust and will interpretation proceedings
- Will contests and fiduciary litigation
- Bank and trust company compliance support
Let's Discuss Your Future
Align your legal, tax, and financial priorities with a single dedicated partner. Call Frost Law at (410) 497-5947 or fill out our contact form to schedule a confidential strategy session.
Get in touchFrequently Asked Questions
Frost Law Private Client Services are tailored to your individual or business needs. They can include estate planning, business succession, international tax compliance, fiduciary administration, and charitable giving. The questions below use plain language to explain the trusts, tax forms, and planning strategies that come up most often in this practice so you can understand what a given tool does before deciding whether it fits your situation. If we haven't answered all of your questions here, please call us at (410) 497-5947 or schedule a confidential consultation.
A Private Client Services practice consolidates the services that high-net-worth families and business owners typically manage through separate, disconnected advisors – estate planning, tax planning, business law, and international compliance. At Frost Law, we bring tax, estate planning, and business attorneys together under one roof, coordinated with an affiliated fiduciary wealth management firm. This integrated approach matters most when your concerns span multiple states, multiple entities, or multiple countries.
Succession planning should generally begin years before an owner intends to exit. This is because the tax and legal structures that produce a favorable outcome, such as entity restructuring or a valuation freeze, need time to take effect before a sale or transfer. The process typically involves choosing between a sale, a family transfer, or an Employee Stock Ownership Plan (ESOP). Business owners who wait until a sale is imminent often lose access to the planning techniques that would have reduced their tax bill. Your business succession planning attorney at Frost Law will help you plan the transition, so that your succession plan and personal wealth transfer plan work together.
An estate planning attorney for a high-net-worth family goes beyond drafting a will. The work typically includes structuring trusts to reduce estate and gift tax exposure, coordinating lifetime gifting strategies, planning for generation-skipping transfers, and addressing state residency or domicile issues that affect how much tax a family's estate ultimately owes. For families with a business, real estate, or investments across state lines, the plan also has to anticipate how those assets pass to heirs without triggering unnecessary tax or probate delay. Frost Law's Private Client Services group builds these plans with attorneys who are also CPAs, so the tax modeling behind a gifting or trust strategy is handled in the same conversation as the legal drafting.
A buy-sell agreement is a contract among a company's owners that sets the terms for what happens to an owner's interest when they die, become disabled, retire, or want to sell. Without one, an owner's death or departure can leave the remaining owners in business with an heir, an ex-spouse, or an outside buyer they never intended to partner with. The agreement is typically funded with life insurance so the purchase can actually happen without straining the company's cash flow. Your buy-sell agreement attorney can draft an agreement alongside your estate plan, so that all the details fit within your personal wealth transfer strategy.
The Foreign Investment in Real Property Tax Act (FIRPTA) requires a buyer purchasing U.S. real estate from a foreign seller to withhold a percentage of the sale price and send it to the IRS. The withholding rate is commonly 15 percent of the gross sales price, though it can be reduced with proper planning and IRS applications in certain situations. Both the buyer and the seller face risk if FIRPTA is handled incorrectly, since the buyer can be held personally liable for the withholding the IRS never received. Frost Law's international tax attorneys handle FIRPTA withholding certificate applications and structure transactions in advance so foreign sellers are not over-withheld and buyers are not exposed to liability.
A Passive Foreign Investment Company (PFIC) is a foreign entity that earns most of its income passively, such as a foreign mutual fund or holding company. The IRS taxes U.S. investors in such entities under punitive default rules unless an election is made. Without proper elections, gains and certain distributions can be taxed at the highest ordinary income rate, plus an interest charge that treats the tax as though it should have been paid years earlier. Many U.S. taxpayers with foreign retirement accounts or investment accounts hold PFICs without realizing it, since the label has nothing to do with how the investment is marketed. Frost Law can identify PFIC exposure in your foreign holdings, and we'll make the qualified electing fund or mark-to-market elections that can substantially reduce your tax and reporting burden going forward.
Puerto Rico Act 60 offers financial benefits to individuals and companies that relocate to Puerto Rico and meet residency and business requirements. The benefits include reduced tax rates and favorable treatment of certain investment income. Qualifying generally requires becoming a bona fide Puerto Rico resident, which involves spending sufficient time on the island and shifting the center of one's economic and personal life there. The incentives have drawn significant IRS scrutiny in recent years, making compliant structuring and documentation essential rather than optional. Frost Law can work with you to document your relocation and residency, and we'll represent you if your Act 60 status is later questioned or audited by the IRS.
IRS Form 706 is the federal estate tax return. It is filed by the executor of an estate whose gross value, combined with certain lifetime gifts, exceeds the federal exemption amount in the year of death. Even estates below the filing threshold sometimes file Form 706 anyway to elect portability, which lets a surviving spouse use any unused portion of the deceased spouse's exemption. The return is technical and time-sensitive, generally due nine months after death, and errors can trigger an IRS audit of the entire estate. Frost Law can prepare Form 706 filings and also represent executors through any resulting audit.
IRS Form 1041 is the income tax return filed by a trust or a decedent's estate to report income the trust or estate earned, such as interest, dividends, or rental income, during the tax year. The trustee or executor is responsible for filing it. The trust or estate can either pay tax on that income directly or pass it through to beneficiaries via a Schedule K-1, depending on how much was distributed. Missing this filing, or misapplying the distribution rules, is a common source of personal liability for trustees and executors.
Families with foreign assets, foreign income, or non-U.S. family members face reporting obligations that purely domestic families never encounter. This includes FBAR and FATCA filings, PFIC elections, and gift or inheritance reporting when money moves across borders. Estate planning also becomes more complicated, since U.S. estate and gift tax rules treat non-citizen spouses and foreign beneficiaries differently than U.S. citizens. Pre-immigration and pre-expatriation planning, done before a move rather than after, is often the difference between a manageable tax result and a costly one. Your international estate planning attorney can handle this reporting and planning in-house, and keep your international and domestic plans consistent.