Experience Category: International

International Estate Planning Involving US Operations and RE Assets

Evaluation of different strategies for non-US holder of US operational assets and US real estate assets as portion of estate-taxable international holdings.  Laying out benefits and disadvantages of various structural options and implementation of chosen strategy.  Interplay of complexity of estranged spouse on title to certain assets on bequest planning.

Tax Efficient Structure for Panamanian Development

Analysis and recommendation for tax efficient receipt of payments and profits for US citizen developing real estate properties in Panama business zone.  Application of S. 911 rules, debt and equity characterization and look-through vs. corporate taxation of profits on realization of project.

Tax Planning Involving US-UK Resident, Limited Companies and US CFC Rules

Tax analysis and strategic planning involving US citizen living in UK with multiple jurisdictional income streams.  Interplay of sub-chapter S strategies with Limited Company strategies (HMRC) and implications of the application of CFC or FPHC rules to UK-based strategies, along with international discussions of multi-tier strategic individual tax planning.
1 2 3 4