US Pre-Immigration Tax Planning

For foreign nationals looking to relocate to the U.S., we offer pre-immigration planning services. Given the worldwide reach of the U.S. income and transfer-tax systems, timing is essential. Once an individual becomes a U.S. resident for U.S. tax purposes, he or she may be exposed to U.S. income taxes on worldwide income and estate and gift taxes on worldwide assets. With proper planning, a taxpayer’s exposure to these taxes can be minimised.

Our pre immigration tax planning takes place over Zoom.

  1.  During the Zoom call we review all your assets and income streams and explain the US tax treatment
  2. If the US tax treatment is negative we may advise on mitigation strategies
  3.  If the US tax treatment is acceptable, then we leave it as is and move onto the next item
  4. Beyond income taxes, we also discuss potential gift and estate tax consequences and advise accordingly

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We have significant experience assisting our clients with complicated, international tax issues. The following list represents some of the areas in which we have provided both planning and compliance services for our clients:

  • US shareholders of foreign corporations
  • US partners in foreign partnerships
  • US grantors and beneficiaries of foreign trusts
  • US shareholders of Passive Foreign Investment Companies (PFICS)
  • Reporting for Foreign Bank and Financial Accounts (FBARs)
  • Blocked income reporting for deferral of tax in currency restriction situations
  • Donations to foreign charities by US private foundations via expenditure responsibility grants
  • Income tax treaty analysis for various issues including determination of residency, re-sourcing of income to avoid double taxation, reduction or exemption of tax
  • Determination of residency for income tax purposes for foreign nationals including optimization of elections for first and last year of residency
  • Social Security tax implications to compensation of foreign nationals and US expatriates including application and analysis of Totalization agreements
  • Foreign tax credit optimization including analysis of paid versus accrued methods and maximizing foreign source income
  • Optimization for US expatriates including analysis of foreign tax credit versus foreign earned income exclusions
  • Reporting of foreign rental properties including proper depreciation methods and treatment of rental of principal residence
  • Reporting and planning for nonresidents with US investments or US effectively-connected income
  • State residency and domicile issues for foreign nationals and US expatriates
  • Reporting gifts and inheritances from nonresidents
  • Consulting to employers of international assignees relating to tax equalization policy development and application, tax planning for international assignments including coordination with tax advisors in local jurisdictions, compensation structuring, payroll reporting and employee education and tax return preparation
  • Determination of residency for US citizens in US possessions