Our Expertise

International Tax, Residency & Structuring Services

From entity formation to banking infrastructure, we design and implement compliant cross-border structures for entrepreneurs, investors, and family offices.

FOUNDATION

Corporate & Tax Structuring

Entity formation is the foundation of every international structure. We design corporate architectures that minimize your effective tax rate while satisfying substance requirements, CFC rules, and transfer pricing regulations in every jurisdiction involved. The difference between tax efficiency and tax exposure often comes down to how entities connect, not just where they're registered.

Common Solutions

International Entity Formation (LLCs, IBCs)
US LLC Structuring for Non-Residents
Holding Company Structures
Intellectual Property Migration
Transfer Pricing & Economic Substance

A compliant structure isn't just about where you incorporate. It's about how every entity, contract, and payment flow connects across jurisdictions.

Client Work

Corporate Structuring Case Studies

How we've structured real cross-border entities for closely-held companies. Identifying details anonymized for confidentiality.

Case 01 · Corporate

Brazilian Agribusiness Export Group: US Parent Structure for Capital Access & Trade Finance

Family-owned Brazilian agricultural commodities exporter with operating subsidiaries in Mato Grosso and a logistics arm at the Port of Santos. Mid nine-figure annual export revenue.

The Challenge

International contracts fragmented across Brazilian entities limited access to trade finance lenders and made due diligence painful for a prospective minority investor. Brazilian withholding taxes on cross-border payments and an opaque corporate structure were hurting lender pricing.

Our Approach

Designed a Delaware holding company above the Brazilian subsidiaries, rebuilt transfer pricing around Brazil's Law 14,596/2023 OECD rules, and structured Section 901 Foreign Tax Credit planning to mitigate double taxation in the absence of a US–Brazil treaty. Subpart F / GILTI managed via Section 962 election for US-resident shareholders.

Outcome

Access to US trade finance facilities at improved pricing, a clean cross-border structure ready for minority equity sale, and a projected reduction in effective group tax leakage on intercompany flows.

Brazil → USTrade FinanceTransfer Pricing

Case 02 · Corporate

European SaaS Founders: Delaware C-Corp Flip for US Series A

Two co-founders of a European B2B SaaS company with a growing US customer base and ARR approaching eight figures, preparing a Series A round from US venture capital investors.

The Challenge

US VCs required a Delaware C-corp at the top of the cap table before committing capital. The founders needed to re-domicile the parent without triggering personal tax on the value shift, without losing IP ownership, and without disrupting EU operating continuity.

Our Approach

Structured a share-for-share exchange under EU Merger Directive principles, making the flip tax-neutral for founders. IP retained in the EU OpCo under an arm's-length license to the Delaware parent, completely bypassing ATAD exit tax exposure that transferring IP would have triggered.

Outcome

Series A closed with a US lead investor on standard terms. Founders preserved pre-flip tax basis, retained IP ownership economics, and kept the EU team operating without disruption.

EU → USC-Corp FlipIP Structuring

MOBILITY

Residency & Citizenship Planning

Where you live determines how you're taxed. We help entrepreneurs and investors establish tax residency in jurisdictions that align with their financial goals. Every situation is different, so we never recommend a one-size-fits-all solution. Whether you're considering Paraguay for its territorial system, the UAE for zero income tax, Italy, or other jurisdictions, we evaluate each option against your full financial picture before recommending a path.

Common Solutions

Residency by Investment (Golden Visas)
Citizenship by Investment (CBI)
Tax Residency Optimization
Second Passport Acquisition
Relocation Concierge Services

Your tax residency is the single most consequential decision in international structuring. We make sure you choose based on analysis, not marketing.

Client Work

Private Wealth Case Studies

How we've designed tax-efficient residency and wealth structures for post-exit founders. Identifying details anonymized for confidentiality.

Case 03 · HNWI

UK Founder Post-Exit: UAE Relocation & Offshore Trust Structure

A UK-resident founder who sold a profitable technology business for approximately £8M, with additional rolled equity in the acquirer. Married with school-age children, seeking a zero-tax long-term base and a durable wealth structure for succession.

The Challenge

UK capital gains tax on the exit was the immediate concern, compounded by the UK's April 2025 shift to a residence-based tax system. The old non-dom regime was replaced with a 10-year UK residency threshold for global IHT exposure, plus a 10-year tail that keeps ex-residents exposed after departure.

Our Approach

Sequenced the exit and relocation so both the sale and the Cayman trust settlement occurred before the family hit the 10-year UK residency mark, permanently severing global IHT exposure. UAE residency established via Dubai Golden Visa, with banking, schooling, and family governance coordinated.

Outcome

Clean UK tax exit, zero ongoing UK income or capital gains exposure on foreign assets, and a durable trust structure insulating family wealth from future UK inheritance tax regardless of the children's eventual residency choices.

UK → UAETrust StructureIHT Planning

Case 04 · HNWI

Spanish Founder Post-Exit: Italy €300k Flat Tax Regime Relocation

A Spanish tech founder who sold a SaaS business, retaining a meaningful liquid portfolio plus minority rolled equity. Wanted to remain inside the EU for family and cultural reasons but escape Spain's high marginal tax on investment income and dividends.

The Challenge

Spanish exit tax on unrealized gains in significant shareholdings was a live exposure, and Spain's wealth tax regime made staying unattractive. The client wanted a tax-efficient EU base with Schengen mobility and a regime that would cap tax on foreign investment income predictably for years to come.

Our Approach

Applied Italy's Article 24-bis flat tax regime for new residents (€300,000/year under the 2026 Budget Law for clients relocating from January 1, 2026). Spanish exit tax deferred under the intra-EU/EEA mechanism of Article 95 bis until actual disposal of the shares, rather than on departure.

Outcome

Predictable €300k/year cap on Italian tax for foreign investment income over the 15-year regime period, Spanish exit tax deferred, wealth tax exposure eliminated, and a stable EU base with full Schengen access.

Spain → ItalyFlat Tax RegimeExit Tax Deferral

PROTECTION

Asset Protection & Privacy Structures

Protecting wealth across borders requires structures that balance privacy with compliance. We design trust, foundation, and holding arrangements that shield assets from litigation, political risk, and creditor claims, while maintaining full regulatory compliance. The goal is privacy but as importantly, legal separation between personal liability and accumulated wealth, structured to hold up under scrutiny.

Common Solutions

Offshore Trust Formation
Private Interest Foundations
Nominee Director Services
Anonymous Holding Structures
Litigation Firewalls & Estate Planning

Effective asset protection is built on legal substance, not opacity. Every structure we design is defensible, compliant, and built for the long term.

LIQUIDITY

Cross-Border Banking & Finance

Banking is where most international structures fail. We leverage a network of banking relationships across stable jurisdictions to open corporate and private accounts, set up merchant processing, and create compliant on/off-ramps for digital assets. If you've been declined by banks due to your structure, jurisdiction, or industry, that's where we start.

Common Solutions

International Corporate Bank Account Opening
Private Banking Introductions
High-Risk Merchant Processing
Crypto-Friendly Banking Solutions
Multi-Currency Treasury Management

We solve the banking problem that stops most international structures from becoming operational.

Client Work

Business Owner Case Studies

How we've helped owner-operators expand across borders, restructure before a sale, and access capital and banking relationships in new markets. Identifying details anonymized for confidentiality.

Case 05 · SMB

Mexican Family Manufacturer: US Market Expansion via Texas Holding

A second-generation family-owned Mexican industrial manufacturer, revenue in the low eight figures (USD), expanding distribution into the US market while owners retained Mexican tax residency.

The Challenge

The family wanted a clean US entity to sign customer contracts and employ US sales staff, without accidentally creating a taxable Mexican presence in the US for the parent or exposing the owners personally to US tax residency. Transfer pricing on inventory flowing from Mexico had to be defensible, and the structure needed to be ready for eventual PE investment.

Our Approach

Established a Texas operating entity under a US holding company, structured so owners retained Mexican tax residency without creating a US Permanent Establishment for the parent. Applied US–Mexico treaty Article 10, securing the 5% dividend withholding rate (Mexican parent owning at least 10% of the US entity). Transfer pricing on cross-border inventory benchmarked and documented to defend against IRS reallocation.

Outcome

Functional US commercial presence launched within the fiscal year, defensible transfer pricing documentation in place, the 5% treaty dividend rate secured, and a structure ready to accept PE diligence or a strategic sale of the US arm.

Mexico → USTreaty PlanningTransfer Pricing

Case 06 · SMB

Canadian SMB Owner: Pre-Sale Restructuring & UAE Relocation

Sole owner of a Canadian services business with revenue around CAD$30M and a clear path to sale within 18 months. Focused on maximizing after-tax proceeds while preparing a long-term personal base outside Canada.

The Challenge

Canadian departure tax on unrealized gains in the private company shares was the largest exposure. Leaving before the sale would crystallize the gain at departure; selling as a Canadian resident would trigger full Canadian tax on proceeds. The client needed a sequence that minimized total tax across both events.

Our Approach

Executed a Section 85 rollover transferring operating company shares into a new Canadian holding company, crystallizing the Lifetime Capital Gains Exemption (CAD $1.25M, raised in June 2024) at the shareholder level before any departure tax could apply. UAE residency established post-sale. Post-departure distributions structured under the Canada–UAE treaty to minimize Part XIII non-resident withholding.

Outcome

Materially reduced total Canadian tax on the combined sale-and-exit path compared to a straightforward sell-and-leave, a stable UAE base for the owner, and ongoing flexibility on distributions from the Canadian holding company.

Canada → UAESection 85 RolloverLCGE Planning

PRESERVATION

Legacy & Succession Planning

Multi-generational wealth requires structures that outlast any single family member. We design succession architectures using trusts, foundations, and governance frameworks that ensure tax-efficient wealth transfer across jurisdictions and generations. This isn't estate planning in one country. It's coordinating inheritance laws, tax treaties, and family governance across every jurisdiction where assets sit.

Common Solutions

Multi-Generational Dynasty Trusts
Family Charters & Governance
International Will Drafting
Probate Avoidance Structures
Philanthropic Foundations

Succession planning across borders means accounting for every jurisdiction's inheritance rules, not just your home country's.

Related Insights

CFC RulesUnderstanding CFC Rules and Economic Substance Requirements Tax StrategyWhy US LLCs Create Tax Problems for UK and Canadian Residents ComplianceThe Reality Check on Offshore Trusts and Foundations

Managing multi-generational, multi-jurisdictional family wealth?

Learn about our dedicated Family Office practice

Not Sure Where to Start?

Most clients need solutions across multiple service areas. A residency change often triggers entity restructuring, which requires new banking relationships, which benefits from asset protection planning. We design integrated structures, not isolated services.

Schedule Consultation

Start with a focused conversation.

Discuss your circumstances, identify the questions that matter and determine the next steps.

Initial advisory consultation

$250 / 30 minutes

Tell us briefly about your situation. Our team will follow up to arrange your consultation.

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