International Tax Planning for US and non-US Clients
Full Legal Support & Counselling
Today, the affairs of high-net-worth individuals and families are global – with assets, businesses and family members located worldwide.
Effective international tax planning and structuring is critical to ensure seamless management and transfer of holdings that may include companies, real estate, marketable and non-marketable investments, private vessels and aircraft, artwork and other collectibles.
While international tax issues might be complex, proper structuring also presents tremendous opportunities – both to reduce the effective tax rate and grow successful business.
Represented a foreign client in setting up an irrevocable trust in New York for purchasing and holding real estate in Manhattan for the benefit of the client's family
Represented a foreign private fund in connection with corporate and tax structuring of investment in commercial real estate project in NYC utilizing beneficial tax treaty provisions and combination and debt and equity
Represented a leading global gold retailer in connection with planned relocation to the U.S. and advised on corporate restructuring, asset restructuring and tax optimization of worldwide operations
Represented a client in connection with planned relocation to the U.S. and designed a two-tier Maltese operating structure in order to defer U.S. income taxation and ensure preferred dividend distribution rates
Advised a foreign client on structuring a reverse 1031-Exchange for the sale of $5M mixed-use property in Midtown Manhattan
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 plannin
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:
- U.S. Pre-Immigration Tax Planning for High-Net Worth Individuals & Families
- Income From Abroad is Taxable – Internal Revenue Service
- Deferral of Income Earned Through U.S. Controlled Foreign Corporations
- Foreign Investment in New York Real Estate: Tax & Legal Guide
- International Tax: DOT – Resources, including signed U.S. Income Tax Treaties, documents related to the implementation of FATCA and International Income Taxation
- IRS International Tax Gap Series
- IRS Resources for International Tax Payers
- Treaties and Tax Information Exchange Agreements (TIEAs)
- International Comparisons of Corporate Income Tax Rates
- Additional International Tax Documents (DOT)
- International Tax Counsel | US Department of Treasury
- IRS: International Tax Payers Resources
- Issues in International Corporate Taxation