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:

• U.S. Pre-Immigration Tax Planning for High-Net Worth Individuals & Families
• Income From Abroad is Taxable – Internal Revenue Service
• Deferral of Income Earned Through U.S. Controlled Foreign Corporations
• Foreign Investment in New York Real Estate: Tax & Legal Guide
• International Tax: DOT – Resources, including signed U.S. Income Tax Treaties, documents related to the implementation of FATCA and International Income Taxation
• IRS International Tax Gap Series
• IRS Resources for International Tax Payers
• Treaties and Tax Information Exchange Agreements (TIEAs)
• International Comparisons of Corporate Income Tax Rates
• Additional International Tax Documents (DOT)
• International Tax Counsel | US Department of Treasury
• IRS: International Tax Payers Resources
• Issues in International Corporate Taxation