Pre-Immigration Planning

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

Represented a client in connection with planned relocation to the US 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 establishing an irrevocable trust structure to purchase and hold $12.5 million in Manhattan real estate for the benefit of the investor’s family members prior to U.S. tax residency

Minimizing U.S. Income Taxation:

  • Exploring strategies to benefit from the step-up in basis of assets to their fair market value so that only appreciation will be taxable once client becomes a U.S. tax resident
  • Accelerating income and accelerating recognition on account receivables prior to becoming a U.S. tax resident
  • Accelerating gain in appreciated assets (real estate assets, artwork, corporate stocks, options, etc.) prior to becoming a U.S. tax resident
  • Deferring losses until after a client becomes a U.S. tax resident
  • Disposing or restructuring foreign corporations with passive income to avoid “Subpart F” and other applicable regimes
  • Planning with trusts as a non-resident can make irrevocable gifts to non-U.S. persons in trusts with proper structuring and avoid U.S. income taxes on future income earned by the trust and U.S. gift and estate taxes on transfer of such assets

Minimizing Exposure to the U.S. Gift & Estate Taxation:

  • Planning with irrevocable discretionary U.S. trusts for the benefit of taxpayer or family members to ensure that assets will not be subject to U.S. estate tax on the taxpayer’s death (life insurance could be purchased to minimize income tax as well)
  • Planning with foreign irrevocable trusts
  • Planning with gifts to U.S. persons and between spouses prior to becoming U.S. tax resident

Pre-Immigration Tax Planning Resources:

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