Concepción Global
A Law Firm serving as a bridge between the Americas and Europe
Practice Areas
International Commercial Arbitration
U.S. citizens and residents are taxed on their worldwide income, regardless of where they live. American individuals living abroad — whether in Spain, France, Latin America, or elsewhere — face significant U.S. tax reporting obligations and planning opportunities, including PFIC exposure from foreign investment vehicles, Net Investment Income Tax, and dual-filing compliance. We help U.S. persons structure their global affairs in a tax-efficient and fully compliant manner.
International Tax Compliance
U.S. persons with foreign financial accounts, interests in foreign entities, or ownership of foreign trusts face an extensive array of annual reporting and disclosure obligations. The penalties for non-compliance can be severe — in some cases exceeding the value of the underlying asset. We help individuals and businesses understand their obligations and achieve and maintain full compliance.
U.S. Real Estate Tax Planning for Foreign Investors
U.S. real estate is one of the most popular investment classes for internationally mobile and foreign individuals — but it carries significant U.S. tax complexity. FIRPTA withholding, U.S. estate and gift tax exposure for non-resident aliens, income tax on rental income, and classification of LLC interests as U.S.-situs assets all require careful planning. We structure U.S. real estate holdings to minimize tax friction while achieving the client’s investment and succession goals.
Pre-Immigration Tax & Estate Planning
The moment a foreign national becomes a U.S. tax resident — whether through a green card, long-term visa, or simply spending enough days in the United States — the full weight of U.S. worldwide taxation applies. What many do not realize is that the planning window is before that moment. Once U.S. tax residency is established, many of the most powerful restructuring opportunities are gone. We work with individuals, families, and their advisors in the months and years before immigration to structure foreign assets, business interests, trusts, and usufruct arrangements to minimize the U.S. tax burden going forward.
Tax Planning for International Entertainers & Athletes
International entertainers and athletes face some of the most complex tax situations of any individual taxpayer. Touring income earned across multiple countries, image rights and licensing arrangements, endorsement deals, foreign withholding taxes, and treaty-based exemptions — all layered on top of the standard U.S. international tax framework — require advisors who understand both the technical rules and the practical realities of a performance-based, globally mobile career.
FATCA & Foreign Financial Institution Compliance
The Foreign Account Tax Compliance Act (FATCA) imposes significant classification and reporting obligations on foreign financial institutions (FFIs), non-financial foreign entities (NFFEs), and the U.S. persons connected to them. Misclassification or non-compliance can result in 30% withholding on U.S.-source payments. In a world where FATCA, CRS, and bilateral tax information exchange agreements operate in parallel — automatically sharing account data across more than 100 jurisdictions — FATCA compliance is not optional, and non-compliance is increasingly visible.
Investor-State Arbitration
Advising and representing investors and states in treaty-based disputes under ICSID, UNCITRAL, and other frameworks involving bilateral and multilateral investment treaties.
Outbound Tax Planning
Offshore Voluntary Disclosure & Streamlined Procedures
U.S. taxpayers who have not reported foreign bank accounts, foreign income, or foreign financial assets face serious civil — and in some cases criminal — exposure. FATCA and the OECD Common Reporting Standard have made undisclosed offshore accounts increasingly visible to the IRS; the assumption that foreign accounts will remain undetected is no longer realistic. We guide clients through the IRS’s available compliance pathways with discretion, strategy, and a focus on achieving the best possible outcome — before the IRS makes contact.
Cross-Border Inheritance Matters
When a family member passes away and assets, heirs, or both span multiple countries, the U.S. tax implications can be significant — and easy to miss without specialized counsel. Cross-border inheritance matters sit at the intersection of U.S. estate tax, income tax, and international information reporting. For non-resident aliens who hold U.S.-situs assets at death, even modest holdings can trigger U.S. estate tax liability, banking freezes, probate proceedings, and IRS transfer certificate requirements — a system that is difficult to navigate without planning.
International Trust & Estate Planning
High-net-worth individuals and families with connections to multiple countries face unique challenges in structuring their wealth for both tax efficiency and generational transfer. Foreign trusts, offshore entities, civil law structures such as usufructs, and internationally mobile beneficiaries all create layers of U.S. tax complexity. The distinction between foreign grantor and foreign nongrantor trusts — which determines who is taxed on trust income, how distributions are treated, and whether the throwback rules apply — is central to any cross-border planning engagement.
Cross-Border Business Structuring for Closely Held Companies
Entrepreneurs and families who own closely held businesses — whether expanding a U.S. business abroad or bringing a foreign business into the United States — face a distinct set of international tax challenges. Relocating a U.S. business owner to a foreign jurisdiction introduces permanent establishment risk, dual-filing obligations, and entity classification issues that must be addressed from the outset. The wrong structure can trigger unexpected U.S. tax costs, double taxation, or reporting penalties; a strategy that works aligns the business structure with the individual’s residency from the beginning.
Inbound Tax Planning
Non-U.S. individuals and businesses investing in or relocating to the United States face a complex web of U.S. tax rules that, if not properly navigated, can result in unexpected tax costs, withholding, and penalties. We advise foreign nationals, non-resident aliens, and internationally mobile individuals on structuring their U.S. activities and investments in a tax-efficient manner.
Representing parties in complex cross-border commercial disputes under ICC, ICDR/AAA, UNCITRAL, and ad hoc rules across multiple jurisdictions and legal systems
Expatriation Tax Planning
Renouncing U.S. citizenship or relinquishing a green card after long-term residency triggers one of the most complex and consequential tax events in U.S. tax law — the exit tax under Section 877A. Without careful planning, expatriation can result in a deemed sale of all worldwide assets and significant tax liability. We guide clients through every stage of the expatriation process, from initial analysis through final compliance.
Concepción Global is a distinguished law firm with an international presence and strategic offices in Miami and Madrid.
We specialize in various facets of international law, including international business disputes, commercial and investor-state arbitration, international tax and estate planning, as well as civil and criminal tax controversies.
