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.
In an increasingly interconnected world, high-net-worth individuals and families manage global portfolios—spanning assets, businesses, and family members across multiple jurisdictions.
These changes present both challenges and opportunities for optimizing tax strategies.
Effective international tax planning and structuring are more critical than ever to ensure the seamless management and transfer of diverse holdings (such as companies, real estate, investments, private vessels, aircraft, artwork, and other collectibles), while navigating heightened IRS enforcement and shifting compliance requirements.
Our experience in cross-border taxation empowers clients to reduce effective tax rates, leverage tax treaties, and grow successful businesses through tailored solutions.
ATTORNEYS' EXPERIENCE
ATTORNEYS' EXPERIENCE
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
ATTORNEYS' EXPERIENCE
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
ATTORNEYS' EXPERIENCE
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
ATTORNEYS' EXPERIENCE
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
ATTORNEYS' EXPERIENCE
Advised a foreign client on structuring a reverse 1031-Exchange for the sale of $5M mixed-use property in Midtown Manhattan
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.
Swiss Bank Accounts for U.S. Residents
We assist U.S. residents with opening bank accounts in Switzerland and Liechtenstein in compliance with IRS regulations and FBAR reporting requirements.
Resources for International Families & Businesses:
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.
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.
For a consultation about international tax planning solutions -
contact international tax attorneys at Dilendorf Law Firm by email or call 212.457.9797
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