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.
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.
Corporate Structuring Case Studies
How we've structured real cross-border entities for closely-held companies. Identifying details anonymized for confidentiality.
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.
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.
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.
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.
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.
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.
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.
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.
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.
Private Wealth Case Studies
How we've designed tax-efficient residency and wealth structures for post-exit founders. Identifying details anonymized for confidentiality.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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 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.
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.
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.
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.
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.
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.
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.
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.