Grant, Herrmann, Schwartz & Klinger LLP | David Sahargun | News & Publications
Established 1946
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David  M. Sahargun


Wealth and Succession Planning
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International Transactions
Tax Planning
Foreign Investment in US Real Estate
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  • American University, J.D.
  • Universidad Pontificia Comillas, Master en Derecho de la Empresa
  • University of California, Berkeley, B.A. (High Honors)


New York
David M. Sahargun
Tel: (212) 682-1800
Fax: (212) 682-1850
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    The Internal Revenue Service has issued guidance that provides relief to foreign individuals impacted by COVID-19 emergency travel disruptions. Revenue Procedure 2020-20 provides that certain foreign nonresident individuals may exclude up to 60 days of presence in the United States for purposes of determining their U.S. tax residency during 2020 and for determining their qualification for certain tax treaty benefits.

  • Single-Member Foreign-Owned LLC Reporting Obligations


    The United States Treasury Department and Internal Revenue Service (IRS) issued final regulations in December of 2016 that now subject foreign-owned single-member limited liability companies (LLCs) that are disregarded for U.S. income tax purposes (i.e., LLCs that have not elected to be classified as corporations) to the informational reporting requirements established under Internal Revenue Code (IRC) Section 6038A for 25% foreign-owned United States corporations. The new regulations now generally require foreign-owned single-member LLCs to obtain a U.S. employer identification number (EIN) and annually file a pro forma Form 1120 corporate income tax return together with Form 5472 identifying each 25% or greater direct and ultimate indirect foreign owner. The first filings pursuant to the new regulations will generally be due as early as April 17, 2018, covering tax years starting in 2017. The IRS will assess a penalty of $10,000 for each year the new reporting requirement is not timely satisfied.

  • FATCA Update: IRS Expands List of IGA Countries
    April 11, 2014

    Update by David M. Sahargun

  • Inversiones Inmobiliarias en EEUU
    January 2014

    Memorandum by David M. Sahargun

  • U.S. Tax Issues Affecting Mexican Clients
    November 12, 2013

    Presentation by David M. Sahargun