PRACTICE AREA
Outbound Tax Planning
U.S. Tax Planning for Americans Living, Working, and Investing Abroad
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.
Our Services Include:
Tax planning for U.S. citizens and residents living or working abroad
Investment portfolio structuring for U.S. citizens abroad — avoiding PFIC classification and managing Net Investment Income Tax (NIIT)
Structuring of foreign business interests — Subpart F, GILTI, PFIC, and CFC analysis
Permanent establishment risk analysis for U.S. citizens operating U.S. businesses from abroad
Compensation and entity structuring for U.S. business owners relocating to foreign jurisdictions
Foreign tax credit planning and optimization
U.S. tax treaty analysis and treaty position planning
Planning for U.S. persons with interests in foreign trusts, estates, and partnerships
Foreign entity classification and check-the-box elections