International tax planning involves cross-border transactions, which requires knowledge of international tax laws to achieve optimal results. Without proper planning, there may be larger tax payments and compliance costs.
At Morris Law Group, we have the expertise required to design a Wealth Preservation Solution℠ tailored to meet your international tax-planning needs. Our firm works closely with business owners, entrepreneurs, real estate professionals, and other high net worth individuals who have complex international tax needs. If you are contemplating expanding your portfolio to include foreign investments, planning additional foreign investments, or wanting to restructure your investments to make them more tax-efficient, we’ll use our extensive knowledge and expertise to create strategic plans that address your specific needs.
The United States Enjoys a Unique Position
From a tax perspective, the United States is unique among highly developed countries in that it continues to tax the income of citizens regardless of where it is earned. In comparison, most other countries only collect taxes on income earned within their borders.
Note that resident aliens who hold a green card or satisfy residency rules are subject to the same tax rules as U.S. citizens. Residency rules state that those who have spent at least 31 days during the current year — and more than 183 days in the past three years — in the United States meet the so-called substantial presence test.
Protecting Your Assets by Considering Every Possible Outcome
Proper tax planning is essential in an international setting to reduce tax consequences that arise due to the lack of consistency in domestic tax systems. To plan an effective tax strategy, you must be able to analyze the formal and substantive requirements of international tax-planning structures in relation to legal, commercial, regulatory, domestic, and international tax rules. An understanding of the interplay of the subject jurisdictions and the impact of relevant tax treaties is essential.
Depending on the jurisdiction that you are coming from or going to, whether or not a tax treaty is in place, and the types of assets you have, there are multiple possible outcomes of any transaction. Taking all of this into consideration, as well as income tax planning and transfer tax planning, we will carefully analyze your situation to advise you on the best options for your personal goals and objectives.
Some of the many issues Morris Law Group can assist with include:
- Developing pre-immigration and expatriate tax-planning strategies for foreign nationals looking to relocate to the United States
- Planning and creating foreign trusts and other entities
- Maintaining compliance with information reporting requirements involving foreign accounts, assets, and interests
- Planning and structuring of inbound foreign investments into the United States, including activities, functions, and ownership risks
- Planning and structuring of outbound foreign investments, including variables such as legal entity structure, repatriation strategies, partnership planning, and the need for a holding company
- Taking advantage of planning opportunities for nonresident, noncitizen individuals (NRA) who may be planning to become residents of the United States
- Interpreting ambiguous rules regarding partnership and LLC interests with respect to the applicability of federal gift tax or estate tax for NRA owners
- Ensuring compliance with estate and gift tax rules while advising on ways to minimize tax liability such as using transfers of intangible personal property such as stock, debt obligations, and other business entities that are exempt from gift taxes
- Creating a Qualified Domestic Trust (QDOT) to ensure that a U.S. citizen spouse receiving an estate from a noncitizen spouse that includes property situated in the United States receives the full marital deduction
Contact Us Today
International tax planning can seem like a complicated procedure if you don’t have the right guidance. At Morris Law Group, our experienced tax attorneys will work with you to ensure that you understand each step of the process and feel empowered to create a roadmap for your financial future. Because our team includes several Certified Public Accountants as well as attorneys with strong accounting backgrounds, you can feel confident we’ll consider your tax-planning issues from an accountant’s perspective as well as a legal perspective.
To discuss your international tax-planning needs, schedule your consultation now. We have four convenient offices in South Florida, including our headquarters in Boca Raton, as well as locations in Aventura, West Palm Beach, and Weston.