International Tax Advisor


U.S. Tax Advice

The United States tax law is the most sophisticated in the world. It is fraught with traps for the unwary.
Accordingly, in addition to providing expert Immigration Law advice for EB5 Visa as well as non-immigrant E2 Visa/L-1 Visa, H-1B and other U.S. visa applicants seeking to move or do business in the U.S., Davies & Associates proactively addresses the client's manifold U.S. tax legal planning needs.
The Immigration Law Counsel and the Tax Legal Counsel provided are fully integrated and tailored to the client's unique global facts and commercial and personal objectives.
By engaging proactively in careful United States income and transfer tax planning both prior to commencement of U.S. tax residency including receipt of Green Card and thereafter, the U.S. visa applicant may thereby substantially mitigate or avoid unexpected adverse U.S. tax costs and thus reduce liability to U.S. taxes, both for the U.S. and global business and personally.

Our solution

By engaging proactively in careful United States income and transfer tax planning during the window period prior to receipt of the Green Card and commencement of U.S. tax residency and thereafter, a client may substantially mitigate or avoid unexpected adverse U.S. tax costs and future IRS tax audit consequences and thereby reduce liability to U.S. taxes.
Our international tax advice for individuals makes the entire process easier for you. Our clients have come to rely on our global tax advice to help guide them through the process of emigrating to the United States or establishing their businesses there.

The United States tax planning services offered by Davies & Associates LLP would cover any, or all, of the following three areas:

A. U.S. Income Tax Planning for the U.S. and Global Business:

U.S. Tax Objective-- To Lower the Global Effective Tax Rate

i. Structuring formation of the U.S. business based on the business plan in a tax-efficient manner including choice of entity and equity ownership
ii. Structuring the U.S. business within the context of global business operations to shield the offshore business earnings of foreign affiliates from United States taxation including imposition of the harsh business profits tax, on the U.S. business profits.
iii. Tax-efficient transfer of the CEO from the overseas entity under the L-1A visa
iv. Structuring ongoing operations of the U.S. business to minimize U.S. tax on business profits
v. Structuring intercompany transactions with foreign affiliates in tax-efficient manner.
vi. Structuring the holding and global exploitation of the Group’s intellectual property {IP} in a tax-efficient manner to reduce U.S. income tax on global profits.
vii. Advising on setting up stock option plan or restricted stock plan for U.S. business in tax-efficient manner.

B. U.S. Federal and State Personal Income Tax Planning ;

i. viii, Advise on U.S. pre-tax residency//pre-Green Card personal income tax planning and restructuring of global assets/investments for client and family for tax efficiency;
ii.
iii. ix. Structuring purchase of U.S. real property or investing in U.S. stocks while Nonresident in tax-efficient manner;
x. Advise on implications of change in United States personal income tax status from Nonresident to Tax Resident including:

  • a. Worldwide personal income tax planning with double taxation relief strategies coordinating with client’s overseas tax advisor;
  • b. Advise on U.S. tax legal impact on existing overseas entities including substantive U.S. tax-efficiency planning for the entity and federal tax reporting requirements; and
  • c. Advise on personal tax reporting requirements re offshore bank accounts and certain other offshore financial assets.

C. Long-term United States Gift and Estate Transfer Tax Planning including Tax-efficient Succession

i. Advise on U.S. transfer tax planning strategies for client and family for tax efficiency prior to U.S. tax residency;
ii. Advise on tax optimization with respect to Offshore Family Trusts prior to U.S. tax residency;
iii. Advising client with respect to lifetime gifting of global properties in tax-efficient manner; and
iv. Life insurance tax planning strategies.

Watch Our Webinar on US Tax Planning

About the Authors

Mark I Davies, Esq.

Chairman of Davies & Associates; focused on E visa strategy and complex consular filings.

Mark I Davies, Esq. JD, University of Pennsylvania Law School, Licensed with the SRA (SRA ID: 384468) in the UK, Member Law Society of England & Wales, MBA, Wharton School of Business. Top 10 Investment Visa Lawyer, Licensed (USA), Georgia State Bar. AILA Member.

Area Details
Education JD, University of Pennsylvania Carey Law School | MBA (Finance), The Wharton School, University of Pennsylvania | Chartered Accountant (ICAEW)
Financial Training Completed Analyst Training Program at a major international bank | Chartered Accountant background with professional training in financial analysis and reporting
Legal Practice Admitted to practice in Georgia (USA) | Registered Solicitor with the Law Society of England and Wales | Former CMBS lawyer at one of the world's largest international law firms
Immigration Track Record 15+ years advising HNW investors | Zero denials for clients advised on source-of-funds compliance in EB-5 | Hundreds of successful EB-5 cases globally
Recognition Named a Top 25 EB-5 Immigration Attorney by EB5 Investors Magazine (2018–2023)
Professional Engagements Lecturer/trainer for other lawyers at AILA, ACA, University of Pennsylvania Law School | Frequent speaker at global investment immigration conferences
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