Practice Area · Cross-Border

Cross-Border Wealth

People move. Assets move. Planning should come first. We advise internationally connected families, founders, investors, and family offices on residency planning, international trust structures, offshore compliance, and cross-border wealth strategies. The most valuable planning happens before U.S. tax residency attaches.

Pre-Immigration Planning · International Structures · Offshore Compliance

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The Problem

The U.S. tax system reaches further than most families expect.

Once you become a U.S. tax resident, the IRS generally taxes your worldwide income. Once you become domiciled in the United States, your worldwide estate may also become subject to U.S. estate tax rules.

Most effective planning occurs before either line is crossed. After that, available options narrow and the cost of planning often increases.

The Cost of Waiting

$60,000 of shelter, 40% exposure

A nonresident who dies owning U.S. property receives only a $60,000 estate tax exemption. On a $1 million U.S. condominium, roughly $940,000 can be exposed to federal estate tax at rates reaching 40 percent.

Planning is most effective before residency or domicile attaches.

What We Do

Compliance. Planning. Mobility.

Each area has its own dedicated practice. Explore where your matter fits.

FBAR / FATCA & Offshore Compliance

Foreign account and asset reporting, disclosure of past filing failures, and defense against IRS penalties.

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Pre-Immigration Tax Planning

Restructuring global assets before U.S. residency attaches, when the planning options are still open.

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Foreign Grantor Trusts

Structuring trusts established by non-U.S. grantors for U.S. beneficiaries.

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Inbound U.S. Wealth Planning

U.S. entry planned as one matter — tax, trusts, entities, and litigation risk decided together, before arrival.

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The Practice

Cross-border planning is a timing problem.

Delay narrows the options. It raises the price of the rest.

Before U.S. residency

The options are open.

Appreciated assets can be sold or repositioned
Gifts of non-U.S. property pass free of gift tax
Foreign entities can be restructured
Trusts can be funded on favorable terms
U.S. property can be structured in advance

After U.S. residency

Most options become limited.

Worldwide income becomes taxable
Worldwide assets face U.S. estate tax
Restructuring triggers tax, not relief
Reporting duties attach, with penalties
What remains is damage control

THE NETWORK

Specialists We Work With.

Complex cross-border matters often require expertise beyond legal counsel. We coordinate the right professionals while maintaining a unified legal strategy.

International Tax Counsel

Treaty analysis, entity classification, and international tax structuring.

Cross-Border CPAs

FBAR, FATCA, and international reporting compliance.

Trust & Estate Counsel

Foreign and domestic trust structures supporting long-term wealth planning.

Local Counsel

Coordination with legal advisors in relevant jurisdictions.

From Our Insights

Start with the rules.

Plain-language guides to the tax and reporting rules that shape cross-border planning.

Offshore Trusts

Offshore Grantor Trusts: The Gift Election That Backfires.

How an incomplete gift election intended to preserve tax treatment can leave assets exposed to creditors, and what it means for Cook Islands structures.

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Compliance

FBAR and FATCA Risks for U.S. Expats.

What foreign account and asset reporting actually requires, where filings go wrong, and the penalties that follow a missed or incorrect return.

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Pre-Immigration

U.S. Pre-Immigration Tax Planning.

Why a nonresident receives only a $60,000 estate tax exemption on U.S. assets, and which strategies close off once residency attaches.

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Questions

Frequently asked.

Before you arrive. This is the single most important point on this page.

Once you become a U.S. tax resident, the IRS taxes your worldwide income. Once you are U.S. domiciled, it reaches your worldwide estate. Most effective strategies must be in place before either happens.

How much time you need depends on your assets and your timeline. Speak with counsel early rather than late.

It can be. A nonresident who is not U.S. domiciled generally receives only a $60,000 estate tax exemption on U.S.-situs assets, such as real estate and certain U.S. securities.

Above that threshold, federal estate tax applies at graduated rates reaching 40 percent. Ownership structure matters a great deal here, and it is easier to fix before death than after.

That depends on the facts, and particularly on whether the failure was willful or non-willful. The distinction drives everything that follows.

The IRS has been narrowing the available relief paths. It eliminated the Delinquent FBAR Submission Procedures in July 2026, and closed the Offshore Voluntary Disclosure Program in 2018.

Do not file quietly and hope. Speak with counsel before making any submission, because the wrong path can create new exposure.

It is a trust established under foreign law by a non-U.S. person who retains certain powers over it. During the grantor’s lifetime, it generally pays no U.S. income tax on non-U.S. source income.

For families where the parents are not U.S. persons but the children are, it can be a foundation for transferring wealth to U.S. beneficiaries. Whether it fits depends on the family, the assets, and the timing.