U.S. Cross-Border Transfer Tax, Income Tax and Charitable Planning
The Private Clients team assists numerous international families and corporate fiduciaries with connections to the United Kingdom, Germany, Italy, France, Switzerland, Brazil, Israel, the U.S. Virgin Islands, and other jurisdictions in dealing with a host of strategic planning issues. These include U.S. income and transfer tax issues, as well as trust and probate issues, arising from foreign investment in U.S. real estate and other U.S. situs assets, migration to and from the United States, the consequences of maintaining permanent residency in the U.S. (i.e., holding a greencard), expatriation and asset protection planning, as well as tax compliance and reporting for U.S. persons with investments outside the United States, related voluntary disclosure proceedings with the IRS, and issues and compliance surrounding U.S. persons with interests in foreign trusts and foreign companies (under the CFC and PFIC regimes). We also help international clients to achieve significant tax benefits through our knowledge of the cross-border regimes regarding residence and domicile.
In addition, the team helps clients find appropriate ways of using their wealth philanthropically, reflecting their personal interests, goals and circumstances, and reducing taxes to a minimum. This can involve the creation of U.S.-qualified, U.K.-qualified and dual U.K./U.S.-qualified charitable structures to support charitable causes and giving by U.S. individuals resident in the United Kingdom. We also advise on the ongoing compliance and operation of charitable structures, including the best ways to involve other family members in the charity. Some of these charities conceive and manage their own projects, while others make grants to support existing organizations.