Structuring Domestic and Offshore Holdings
A major aspect of our international tax practice involves structuring domestic and offshore investment vehicles to act as holding companies for operating businesses or passive investments/assets, and integrating those entities into client’s overall estate and trust planning.
We advice clients on applicable FATCA rules, CRS compliance, PFIC rules and CFC rules.
We understand business and legal intricacies of cross-border taxation and have substantial experience structuring international transactions, operations, holdings and investments, including advantageous use of tax deferral techniques, tax treaties and entity classifications.
From Initial Planning to Implementation – Highly Tailored International Tax Solutions for Each Client
We take time to understand our clients’ personal, professional and business goals and provide highly customized solutions that account for specific situation of each client.
When working with our private clients on tax planning and structuring matters, we always keep the long-term goals in mind and tailor every solution to account for them.
We work with other attorneys, trust professional, accountants and experts worldwide to assist in the implementation of complex structures that include domestic trusts, intra-family gifting for multinational families, offshore corporations, foreign grantor and non-grantor trusts, domestic and international private trust companies, and advice on optimal real estate and cross-border investment structures.
Resources for International Families & Businesses:
2025 Updates
Many key provisions from the 2017 TCJA are set to expire at the end of 2025 unless Congress intervenes. Notably, the 20% Qualified Business Income (QBI) deduction for pass-through entities could be lost, potentially increasing tax rates for individuals and businesses like partnerships or S corporations in 2026. International clients operating U.S. pass-through entities should incorporate this possibility into their 2025 planning.
- Corporate Tax Rate Considerations
While the TCJA permanently lowered the U.S. corporate tax rate to 21%, potential legislative changes are on the horizon. With Republican control of Congress and the White House following the 2024 elections, proposals—such as President-elect Trump’s plan to reduce the rate to 15% for U.S. manufacturers—could impact U.S. subsidiaries. International clients should stay alert for these developments throughout 2025.
- Standard Deduction Increases
For tax year 2025, the standard deductions have been raised:
Single filers and married individuals filing separately: $15,000 (an increase of $400 from 2024). Married couples filing jointly: $30,000 (up by $800). Heads of households: $22,500 (up by $600)
These adjustments may affect tax planning for international clients with U.S. employees or owners.
Taxpayers receiving over $5,000 in payments through online marketplaces or payment apps in 2024 will receive a Form 1099-K in January 2025. International clients using U.S.-based platforms must ensure accurate income reporting as the IRS continues lowering the reporting threshold and ramping up compliance checks.
- Digital Asset Reporting Requirements
U.S. tax obligations now include reporting digital asset transactions—such as cryptocurrency sales or exchanges—on 2024 tax returns filed in 2025. The IRS requires taxpayers to disclose any digital asset activity, reflecting increased enforcement in this area.
The OECD’s Pillar Two framework, which sets a 15% global minimum tax for multinational enterprises with annual revenues over €750 million, is gradually being adopted worldwide. Although the U.S. has not fully embraced Pillar Two, its Global Intangible Low-Taxed Income (GILTI) rules may need adjustments to maintain alignment, impacting tax planning for international clients with U.S. operations.
- Foreign Tax Credit (FTC) and GILTI Considerations
Changes to GILTI rules under a new administration could affect how international clients utilize the FTC to offset U.S. taxes on foreign income. Proposed modifications to align GILTI with Pillar Two may increase the effective tax rate on foreign earnings, requiring strategic planning in 2025.
- Increased IRS Enforcement and Compliance
The IRS is intensifying its enforcement efforts—especially for international tax compliance. Enhanced scrutiny of transfer pricing, withholding tax obligations, and foreign bank account reporting (FBAR) means that international clients must rigorously adhere to U.S. reporting requirements to avoid potential penalties.
For tax year 2025, the AMT exemption amounts have increased:
Unmarried individuals: $88,100
Married couples filing jointly: $137,000 (with phase-outs starting at $626,350 and $1,252,700, respectively)
International clients with U.S. income should review their AMT exposure, particularly if TCJA provisions are allowed to lapse.
General Resources
Summary
Service Type
International Tax Attorney
Provider Name
Dilendorf Law Firm,
85 Broad Street,New York,NY -10004,
Telephone No.212.757.9797
Area
New York, Miami, Florida, Manhattan
Description
International tax attorneys based in NYC assist foreign clients with various tax planning matters, including tax structuring of foreign investment in U.S., pre-immigration tax planning and other investments.
