U.S. tax planning involves working through a maze of complex laws that aim to ensure that no one escapes from paying the tax. For foreign tax planning, the laws are even more complicated. Taxpayers are obligated to pay taxes once, but no more than once.
In addition to setting forth the basic rules, Jacob Stein aims to educate about the most common planning transactions and structures designed to give you a better tax result.
Tax Planning for Foreign Investors
Tax planning for foreign investors requires thorough analysis and careful planning as foreign investors and businesses have several revenue streams to consider when planning taxes such as, Estate and Gift Taxes, tax from income from a U.S. Business or from the sale of U.S. Real Estate, tax on Passive Income and Capital Gains or Branch profits.
Tax Planning Prior to U.S. Immigration
For investors looking to immigrate to the U.S., there is the option of using an EB-5 Visa. However, pre-immigration tax planning is an important step that should not be neglected. Pre-immigration tax planning is three-fold: removing capital gain prior to immigration, structuring ownership of passive assets to avoid U.S. income taxation following immigration, and structuring ownership of all assets to avoid U.S. estate taxation on death.
Tax Planning for Americans Investing Overseas
Americans who operate businesses or have investments abroad are subject to a complex set of taxation. For example, the tax analysis of an American investing in a foreign corporation, or operating a business through a foreign corporation, changes dramatically depending on if the corporation itself does or does not do business in the U.S.