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Tax Lawyers in San Francisco Bay Area
180 Montgomery Street Suite 1950
San Francisco, CA 94104

888 829-3325
415 394-7200

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International Tax Law

Inbound Taxes

  • Investment income from U.S. sources
  • Business income from U.S. sources
  • Branch profits tax
  • Branch interest tax
  • Interest deduction limits
  • Capital gains
  • FIRPTA

Outbound Taxes

Combined Inbound/Outbound Taxes


Offshore Planning

Many Americans utilize offshore entities and structures to protect foreign investments, property, employment arrangements, company or marital ties. People who use offshore entities and structures need comprehensive advice regarding decisions that accompany doing business overseas, such as when to use a limited liability company versus a trust. We regularly advise clients on offshore entity establishment and wealth transfer, applicable government forms and reporting requirements. In addition, we advise clients on strict foreign entity compliance.

Foreign Trusts

An essential element of successful estate planning is an offshore trust that separates assets from a trust settlor since trust assets can be excluded from an individual's estate. Once the wealth has been transferred to a foreign jurisdiction, it becomes exceptionally difficult for a United States (“U.S.”) creditor to recover the assets transferred to the trust. Our firm provides detailed legal advice regarding establishing foreign trusts and how domestic assets can be transferred offshore without violating laws. We also consult individuals with offshore trusts that need to comply with complex U.S. federal law.

Foreign Limited Liability Companies

An individual can place assets, in a foreign LLC, in a jurisdiction that does not permit foreclosure on the membership interest subject to an order. Individuals look to foreign jurisdictions that have an established history of making it difficult for creditors to pierce the veil of an LLC. Our office helps clients to establish LLCs in debtor-friendly jurisdictions. Our goal is to legally protect our client's hard earned assets. Sometimes we advise our clients to utilize tiered LLCs in numerous jurisdictions.

 

 

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