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U.S. Tax Planning
We counsel clients on many aspects of U.S. taxation relating to U.S. federal income taxation of investments in the U.S. and the application of U.S. transfer taxes to U.S. citizens.
U.S. Investments by Non-Residents
Making investments in the U.S., whether those investments be real estate, private businesses or shares in listed companies, have U.S. income and transfer tax considerations. We counsel clients on the proper structuring of investments in order to minimize taxes and achieve objectives. We use a combination of holding vehicle, trust and insurance solutions to accomplish these objectives.
U.S. Income Tax Planning
Persons exposed to U.S. income taxes can benefit from proper planning. We assist clients with U.S. tax planning ranging from the acquisition of businesses, the formation of investment vehicles, tax deferred exchanges and retirement planning.
U.S. Citizens Living Abroad
U.S. citizens living abroad face the same U.S. tax burdens as U.S. residents. We help expatriates plan for both U.S. income and transfer taxes (i.e., U.S. estate, gift and generation skipping transfer taxes) with integration of this planning with the jurisdiction of residence. Expatriates face particular sensitivity to pension, non-qualified deferred compensation and foreign tax credit issues.
Executive Compensation for Expatriates
We counsel companies and U.S. citizen executives on the design of executive compensation programs. Because U.S. citizens remain subject to U.S. taxation whilst abroad, the rules relating to pensions and nonqualified deferred compensation (i.e., certain stock options, restricted stock grants, phantom equity plans, etc.) are subject to special rules. We can advise companies and executives on the design and taxation of such programs.
U.S. Citizens Married to Non-Citizens
Certain provisions of U.S. estate and gift taxes work differently in the context of a spouse who is not a U.S. citizen. U.S. citizens married to non-U.S. citizens require special planning to minimize U.S. estate and gift taxes, including the use of quailed domestic trusts (QDOTs), private annuities and gifting strategies.
U.S. Expatriation
The U.S. imposes an exit tax on certain persons who relinquish their U.S. citizenship or green card. This exit tax involves not only a deemed sale of assets on the date of expatriation but also U.S. estate and gift tax ramifications. We counsel persons thinking of relinquishing their U.S. citizenship or green card on compliance with these rules and guide clients through the entire expatriation process.
U.S. Immigration Planning
Proper planning prior to moving to the U.S. can save U.S. taxes down the road. We help clients analyze their tax basis in assets and implement planning techniques to minimize U.S. income and transfer taxes. Depending on the length of stay in the U.S., the use of deferred variable annuities or life insurance can be attractive to a client. Planning prior to moving to the U.S. is one of the most powerful ways of minimizing future U.S. taxes.
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