PRACTICE AREA
Inbound Tax Planning
U.S. Tax Planning for Non-U.S. Persons and Foreign Investors
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 national, non-resident aliens, and internationally mobile individuals on structuring their U.S. activities and investments in a tax-efficient manner.
Our Services Include:
Pre-immigration tax planning and restructuring of foreign assets and entities prior to becoming a U.S. tax resident
Residency determination and analysis under the Substantial Presence Test and Green Card rules
U.S. income tax planning for non-resident aliens (NRAs) with U.S.-source income
Structuring of U.S. investments through corporations, partnerships, trusts, and other vehicles to minimize U.S. tax exposure
U.S. real estate investment structuring — addressing FIRPTA withholding, income tax, and estate/gift tax exposure for foreign investors
U.S. estate and gift tax planning for non-resident aliens, including treaty-based planning
Advising on U.S. inheritance matters for non-resident alien beneficiaries
Analysis of applicable U.S. income and estate tax treaties