International Tax Planning

Sophisticated tax planning solutions for private clients and their enterprises

Often, tax considerations influence our clients’ decisions to move from one country to another or to invest in or acquire assets in another country, including the United States. Counseling clients on tax planning matters is an integral part of the work done at G.S. Monteiro Law. Our attorneys have an in-depth understanding of the tax needs of our private clients and their family offices, both domestic and international. We work with our clients to minimize exposure to tax for present and for future generations.

U.S. Pre-immigration & Pre-departure (“Expatriation”) Tax Planning

Our firm analyzes the potential U.S. income and transfer taxes of non-U.S. citizen and non-U.S. resident affluent families and high-net-worth individuals in connection with their contemplated move to the U.S. (and U.S. tax residency). We also review their current structures and provide advice on the implementation of tax-efficient strategies. If you are considering moving to the U.S., it is crucial that you implement a detailed tax plan before you move.

U.S. Inbound and Outbound Tax Planning

G.S. Monteiro Law assists our clients by implementing tax-efficient strategies for foreign and domestic affluent families and private clients investing, operating businesses or otherwise creating wealth in the U.S. and across the globe. Our approach takes into account the strategic short-term and long-term goals of our clients. For non-U.S. clients looking to make investments in the U.S., our inbound practice assists with tax structuring to achieve favorable U.S. tax outcomes in relation to investments ranging from pure passive holdings to active trades or businesses. Some of the issues we advise on include choice of entity, permanent establishment exposure, qualification for treaty benefits, minimization of dividend withholding and branch profits tax. We also advise clients on outbound transaction strategies to minimize taxes in the host country, minimize withholding taxes on repatriation of earnings, maximize creditability of foreign taxes against U.S. tax liability, and plan for tax-efficient exits. We have significant expertise with respect to anti-deferral rules under the controlled foreign corporation (CFC) and passive foreign investment company (PFIC) regimes. We have gained significant experience advising clients about the new and complex provisions concerning the foreign-derived intangible income (FDII) deduction, and global intangible low-taxed income (GILTI) under recently enacted tax legislation.

We also consult clients on the tax and corporate law implications of different U.S. business entities and help meet the filing obligations associated with such entities. We have significant experience in corporate tax planning, partnership tax planning, real estate investments, federal and state income taxation and international tax treaties. In particular, we regularly advise clients with respect to tax planning associated with the formation, operation, acquisition and sale of corporations, partnerships and other business enterprises.

International Tax Reporting & Compliance

Governments across the world have substantially increased the requirements in connection with tax and compliance-related informational returns and forms on taxpayers, including the Common Reporting Standards (“CRS”) and U.S Foreign Account Tax Compliance Act (“FATCA”) regimes. GS Monteiro law helps the members of our affluent families who are U.S. citizens and residents under the increased pressure of these regimes, to understand and meet the reporting responsibilities of certain accounts, business interests, receipt of foreign gifts, and other asset classes. So, whether our clients need to file a Form 3520 as the recipient of a large gift, a form 5471 or 8621 in connection with their foreign entities, or a FinCEN Form 114 and Foreign Bank and Financial Accounts, we provide the services to ensure accurate and timely filing of the forms that keep our clients compliant.

As part of the services, the following are some of the areas our attorneys provide assistance with:

Pre-immigration and pre-departure (Expatriation) planning

Planning for Business expansion in the United States

Treaty Planning That Minimizes Global Effective Tax Rate

Strategies To Mitigate Adverse Impact of CFC, PFIC, GILTI and Subpart F Regimes

Foreign Entities and Asset Informational Reporting

Contact Us

Miami
(305) 707-7126
201 alhambra circle,
STE 802,
Coral gables, FL 33134

848 Brickell Avenue
Suite 203
Miami, FL 33131
Phone:786-946-4667
Fax:786-946-4890