International Tax Planning

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.

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)