Connor Southwell has over 15 years of experience in professional tax accounting, with a majority of that time focused on international tax matters.
As a member of the International Tax Services Team, Connor spends most of his time working with individuals and their closely held businesses and succession structures. He has extensive experience with pre-immigration tax planning, expatriation, foreign trusts and estates, outbound and inbound structuring and international tax controversy. His specific areas of tax knowledge include: streamlined offshore procedures, Delinquent International Information Return Submission Procedures (DIIRSP), Delinquent FBAR Submission Procedures, IRS audits, appeals, and offers in compromise pertaining to international reporting and associated penalties, structuring of foreign trusts with U.S. beneficiaries and/or grantors, pre-immigration tax planning for ultra-high-net-worth individuals and their families, and Section 1441, 1445, and 1446 withholdings.
Connor is committed to helping his clients navigate the tax complexities of cross-border transactions and immigration while working closely with foreign accountants and attorneys to achieve optimal tax efficiencies in the United States and abroad.
He holds a Juris Doctor (JD) and LLM in Taxation, with an active license in Virginia and Washington, D.C.
Learn more about my professional experience and how I spend my time outside the firm.
Education:
Professional Affiliations:
Connor lives an active lifestyle, taking an interest in CrossFit, hiking and going to the mountains. He also values family and enjoys spending time with his wife and two children.
Receiving equity from a U.S. company if you are not a U.S. citizen or resident alien can raise questions about how and when that equity is taxed in the United States. For U.S. tax purposes, these individuals are generally referred to as “nonresident aliens” or “non-U.S. persons.” One common consideration is whether to file an…
The IRS is considering a potential overhaul of its Voluntary Disclosure Practice (VDP). This comes after the IRS formally ended the Offshore Voluntary Disclosure Program (OVDP) in 2018. Since then, taxpayers with willful offshore reporting failures must use the IRS Criminal Investigation (CI) VDP, which lacks much of the structure and certainty afforded under the…
Navigating the complexities of international taxation requires a comprehensive understanding of evolving regulations and strategic planning. This overview encompasses key aspects of current tax landscapes that are essential for companies operating internationally. One Big Beautiful Bill Act (OBBBA) International Provisions Major International Tax Changes Made by OBBBA – Effective January 1, 2026: Examination of Select…