International high net worth individuals and their families face exceedingly complex issues and choices. They must consider not only the laws of citizenship and permanent residency, but also the laws in jurisdictions where they have investments or may temporarily reside. To help these families, we understand and provide advice on the tax aspects of a range of situations, including:

Foreign investment by U.S. persons

• Creating foreign investment entities
• Analysis of foreign investments held by U.S. persons to identify applicability of anti-deferral (i.e., controlled foreign corporation (CFC) or passive foreign investment company (PFIC) rules

International executives

• Tax planning for U.S. inbound and outbound (expatriate) executives
• Comprehensive executive financial counseling
• Planning for departure/expatriation from the United States — relinquishing green card or citizenship

International transfer tax planning

• Estate planning with global assets
• Estate planning with non-U.S. citizen spouses
• Planning for foreign nationals investing in the United States
• Life insurance planning

Foreign trusts

• Structuring foreign trusts for U.S. estate planning
• Pre-immigration trusts for nonresident aliens
• Structuring distributions from foreign trusts to U.S. beneficiaries
• Use of asset-protection trusts

U.S. investments by nonresident aliens and non-U.S. families

• Investing in U.S.-based assets — U.S. real estate and other
• Investing in the United States through non-U.S. entities
• Investing in venture capital

Compliance

• Income, gift and estate tax returns
• Compliance and reporting by non-U.S. entities — partnerships and trusts
• Transfers to, and interests in, foreign entities
• Conversion and translation of foreign accounts to U.S. tax principles