International Tax Planning
We counsel clients who are United States citizens or residents in international tax planning matters concerning their ventures in various international locales, including Canada, Europe, South America, Asia, Africa and the Middle East. In these matters, we examine the interaction between the tax structures of the U.S. and foreign nations.
We also represent clients who are not residents or citizens of the United States. For many of these clients, we provide advice on the proper structuring of their U.S. business and investment interests. We also provide counsel to nonresident clients who have one or more family members who have immigrated to the U.S. or are planning to do so. In addition, we actively provide non-U.S. clients with inbound planning by designing estate plans and income tax structures with the objective of minimizing exposure of assets to U.S. gift, estate or income taxes once the client arrives in the U.S.
We have worked with U.S. clients who have foreign trusts in order to deal with the specific U.S. provisions with respect to both reporting and taxation. We also advise beneficiaries of such trusts to determine the appropriate distribution policies in order to minimize the often onerous U.S. tax provisions with respect to accumulated income, including naming a U.S. trustee and making transfers to charity.