Customs & Border Protection (CBP) • Estate & Tax Planning • Cross-Border Compliance & Business

CBP (U.S. Customs) Practice

• Matters handled: detentions/exams (19 U.S.C. §1499), seizures/forfeitures (§1595a), civil penalties and §592 (negligence/gross negligence/fraud), UFLPA forced-labor holds, origin/marking, valuation, classification, IP border measures, and recordkeeping (Part 163).

• Tools & pathways: Petitions/Supplemental Petitions (remission/mitigation), Offers in Compromise (19 U.S.C. §1617), immediate export/transportation (IE/T&E), Prior Disclosures, and HQ rulings (Regulations & Rulings).

• Track record: In 2025, led outcomes totaling ~$5 million in merchandise value released, returned, or CBP-approved for re-export across multiple ports.

• Approach: Business-first and compliance-sound—triage fast and choose the lowest combined time/fee/risk path to release, re-export, or penalty relief.

Estate & Tax Planning
Serving founders, family business owners, cross-border families, and emerging HNW clients with end-to-end planning—from lifetime strategy to trust/estate administration and tax filings.

• Core documents: Revocable Living Trusts (RLT), pour-over wills, durable powers of attorney, advance health care directives, funding checklists for accounts/real estate, beneficiary designations, digital assets, and guardianship plans.

• California community property: Guidance under California’s community-property system on titling, transmutation, and coordination with trusts and business entities.

• Advanced techniques:

  • ILITs (life insurance outside the estate; §2042/§2035; Crummey powers)

  • GRATs (including “zero-out”; §2702; Walton)

  • IDGTs (sales to grantor trusts; Rev. Rul. 85-13)

  • QPRTs (personal residence) and charitable trusts (CLT/CRT; §664; §§170/2522/2055)

  • QDOTs for non-citizen spouses (§2056(d)) and portability planning (§2010(c))

  • Cross-border family structures, FX, and information-reporting alignment

• Tax returns & procedure: Forms 706/709/1041/3520/3520-A, adequate disclosure, valuation support; accuracy-related penalties/defenses (§§6662/6664); IRS/state audits, appeals, payment plans, and IRS OIC (IRC §7122).

• Real property & California property tax: Prop 19/58/193 strategies (primary residence/exclusions), multi-state/LLC/LP/trust ownership, and financing/refinance alignment.

• Administration: California probate; trust accounting & distributions; trustee duties; beneficiary coordination; dispute resolution.

Tax Controversy & International Compliance

• Federal and state income/gift/estate tax audits and appeals; penalty relief and installment/OIC solutions.

• FBAR (FinCEN 114) and FATCA (Forms 8938/8966); foreign trusts/beneficiaries and CFC reporting.

• Business law touchpoints: entity formation and restructuring, equity compensation, M&A and succession, and embedding sanctions/export/data clauses in contracts.

Representative Matters

• E-commerce importer: CBP detention/seizure—evidence package and petition in 10 days, pivot to IE/T&E where needed, achieving release/re-export with reduced storage and penalty exposure.

• Cross-border family: RLT + QDOT + portability + foreign trust reporting for balanced lifetime tax and inter-generational transfer.

• Tech founder: ISO/RSU and QSBS strategy + ILIT liquidity planning + GRAT/IDGT roadmap.

• Family real estate: Property-tax planning under Prop 19, layered LLC/LP + trust structure, improved cash-flow and estate-tax outcomes.

Education & Admissions

• J.D.; LL.M. in Taxation (University of Florida); Master of Law in Chinese Law.

• Admitted in California, Texas, Florida, District of Columbia, U.S. Tax Court; PRC National Legal Qualification (2012).

• Languages: English | Chinese.

Client Service Philosophy

• Outcome-driven: Legal tools serve business goals; solutions must be executable and cost-aware.

• Stabilize, then optimize: Secure release/compliance and stop risk first; then refine structure and tax efficiency.

• Transparent: Clear milestones, fixed/phase fees where appropriate, coordinated workflows with CBP, tax authorities, and courts—fewer detours, faster results.