Private Capital

Structuring Domestic and Offshore Holdings

A major aspect of our international practice involves structuring domestic and offshore investment vehicles to act as holding companies for operating businesses or passive investments or assets, and integrating those entities into the client’s overall estate and trust planning.

We advise 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 the 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:



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

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

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 U.S. 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 structuring a reverse 1031-Exchange for the sale of $5M mixed-use property in Midtown Manhattan

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