Pre-Immigration Tax Planning for Individuals

When am I required to start paying taxes?

Your worldwide income will be subject to taxation in the United States after you obtain your visa or are present in the U.S. for a substantial period of time. There are numerous "tax traps" that you should be aware of as well.

U.S. tax traps include:

  • The built-in gains of your worldwide assets are also subject to taxation.
  • You do not get tax credits for foreign taxes paid by foreign family companies
  • Dividends from non-treaty jurisdictions do not get preferential qualified dividend tax treatment
  • You may become subject to the U.S. exit tax if you acquire a U.S. permanent resident "green card" and later decide to surrender it

What Happens After You Enter the U.S.?

Upon acquiring your Visa or simply being substantially present in the U.S., an individual’s worldwide income is subject to U.S. taxation. To make matters worse, the built-in gains of an individual’s worldwide assets are also subject to taxation, individuals do not get tax credits for foreign taxes paid by foreign family companies, dividends from non-treaty jurisdictions do not get preferential qualified dividend tax treatment, and an individual may become subject to the U.S. “exit tax” if they acquire a U.S. Permanent Resident “Green” Card and later decide to surrender it.

Castro & Co.’s Pre-Immigration Tax Team can implement sophisticated planning strategies that avoid all of the aforementioned U.S. tax traps. Treaty-based planning can allow a U.S. green card holder to be taxed as a nonresident and avoid U.S. taxation on worldwide income, pre-immigration “check-and-liquidate” strategies can synthetically step-up basis in worldwide assets and prevent the U.S. from taxing pre-immigration built-in gain of worldwide assets, tax elections can be made to treat foreign corporations as flow-through entities in order to get direct U.S. foreign tax credits for foreign taxes paid by the company, special purpose holding companies can be established in treaty countries like Belgium to attain qualified dividend treatment, and treaty planning can avoid the U.S. Mark-to-Market “Exit Tax” for long-term green card holders.

Pre-immigration international tax planning strategies will be of extreme importance and interest to EB Series Visa holders since they are typically affluent individuals. Castro & Co. has the knowledge and experience to resolve all of your pre-immigration tax concerns.

Discuss your pre-immigration tax case in a free case evaluation.

Elite International Tax Planning by Miami & Washington DC Tax Lawyers

A Washington DC & Miami international tax attorney from Castro & Co. can help you avoid these traps by implementing sophisticated tax planning strategies. We specialize in international taxation and will work to minimize your taxes and maximize your tax savings.

Ways that you can avoid common U.S. tax traps:

  • Treaty-based planning can allow a U.S. green card holder to be taxed as a non-resident and thus avoid U.S. taxation on worldwide income.
  • Pre-immigration "check and liquidate" strategies can synthetically step-up basis in worldwide assets and prevent the IRS from taxing pre-immigration built-in gain of worldwide assets.
  • Tax election can be made to treat foreign corporations as flow-through entities in order to get direct U.S. foreign tax credits for foreign taxes paid by the company.
  • Special purpose holding companies can be established in treaty countries like Belgium to attain qualified dividend treatment.
  • Treaty planning can avoid the U.S. Mark-to-Market "Exit Tax" for long-term green card holders.

Contact Castro & Co. at (888) 595-5088 for a free consult.

Pre-immigration international tax planning strategies are important. Many of our clients are EB series visa holders. Our firm has the knowledge and experience necessary to help you resolve all of your pre-immigration tax concerns. You can rely on us for superior tax planning strategies and solutions to even the most challenging legal taxation obstacles.

Contact Castro & Co. today to schedule your free case evaluation with a member of our experienced team of international tax attorneys.

Contact Castro & Co. Today

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