International Tax Advisor

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.

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