PRACTICE AREA
Pre-Immigration Tax & Estate Planning
U.S. Tax Planning for Individuals and Families Before They Become U.S. Tax Residents
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 in a manner that minimizes the U.S. tax burden going forward.
Our Services Include:
Pre-immigration income tax planning — identifying and restructuring foreign assets before U.S. residency begins
Basis step-up planning for foreign assets and investments before immigration
Analysis and restructuring of foreign business interests — PFIC, CFC, and check-the-box planning before immigration
Foreign trust analysis and pre-immigration restructuring — grantor trust status, accumulation distributions, and throwback rules
Pre-immigration transfer of bare ownership interests (usufructs) — planning under civil law structures before U.S. estate tax applies
Pre-immigration gift and estate planning — completing transfers before the U.S. gift and estate tax regime applies
Residency timing planning — optimizing the date of U.S. tax residency commencement
Coordination with immigration counsel to align tax and visa planning
Treaty analysis and tie-breaker planning for individuals moving from treaty countries