Our Expertise

One Coordinated View

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.

Tax Residency & Relocation

Move with a complete picture.

Where you live determines how you're taxed, and a move affects more than your address. We look at how personal residency, business ownership, family circumstances and the timing of the move fit together, and we weigh Paraguay, the UAE, Italy or any other destination against your full picture rather than a template. The choice should rest on analysis, not marketing.

Departure planning and the ties you keep with your current country
Comparison of suitable destinations
What the move means for how your business is run and owned
Residency applications, including golden visas, and local coordination

See client work: a UK founder's post-exit move

Corporate & Holding Structures

Structure around how your business works.

Your structure should reflect where decisions are made, where people work and how money moves. The difference between tax efficiency and tax exposure usually comes down to how entities connect, not just where they are registered, so we evaluate the whole arrangement, including substance, CFC rules and transfer pricing, before recommending an entity or a jurisdiction.

Ownership and holding company design, including US LLCs for non-residents
Operating and digital businesses selling across borders
Payment flows, intercompany contracts and transfer pricing
Coordination of reporting and local advisers in each country

See client work: Brazilian, European and Mexican groups

Trusts, Foundations & Succession

Give your wealth a considered future.

Wealth that passes across borders and generations needs a structure that holds up wherever a beneficiary lives or an asset sits. We help families work through the practical choices behind trusts, private interest foundations and family holding arrangements: who controls what, who benefits, and which obligations continue after formation. Asset protection, where it is part of the goal, is built on legal substance, not opacity.

Whether a trust, a foundation or a simpler holding fits your family
Family and beneficiary circumstances, including heirs in different countries
Succession, governance and family charters
Trustee coordination, cross-border wills and probate

Read: The Reality Check on Offshore Trusts and Foundations

International Banking

Make your structure work in practice.

Banking is where most international structures fail, so account requirements belong in the plan from the beginning. We use banking relationships across stable jurisdictions for corporate and private accounts, payment processing and compliant on and off ramps for digital assets. If you've been declined because of your structure, jurisdiction or industry, that's where we start.

Corporate and private banking introductions
Account documentation, ownership information and onboarding
Merchant and payment processing requirements
Treasury and multi-currency considerations

Ongoing Compliance & Advisory

Keep your plan aligned with your life.

A new investment, a family move or a business sale can change what your structure needs to do, and tax law changes on its own schedule. Ongoing support is scoped around your circumstances and the professionals already involved, with the structure reviewed annually and adjusted when something moves.

Reviews after significant changes and an annual structure review
Coordination with your existing accountants and counsel
Reporting responsibilities: who files what, where and when
Follow-through on implementation

Planning a Sale?

Plan the sequence before the sale.

A sale brings personal and corporate decisions into a short window, and the order in which you sell, restructure and move decides how much tax each step carries. We work from the expected deal, any interests you keep and where you intend to live afterwards.

Ownership and the transaction timeline
Personal residence and relocation plans
Sale proceeds, retained equity and future payments
Coordination with transaction counsel and accountants

See client work: a Canadian owner's pre-sale restructuring

Client Work

Recent Engagements

Six recent engagements across corporate structuring, private wealth and business sales. Identifying details anonymized for confidentiality.

Corporate Structuring

How we've structured real cross-border entities for closely-held companies.

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

Private Wealth

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

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

Business Owners

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

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

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

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