Moving across borders can change how income, investments and wealth are taxed, often substantially. The decisions that matter most are usually the ones taken before US tax residency begins, or before US status is given up, because once the date passes most of them cannot be reversed.
We work with entrepreneurs, executives, investors and globally mobile families on planning the move in both directions, looking at residency, asset ownership, business interests and succession together so the position stays efficient through the transition.
Mobility Planning
Pre-Immigration Planning
The period before becoming a US tax resident offers the most valuable planning opportunities. We review investments, ownership structures and wealth arrangements ahead of the move, addressing PFIC exposure (including many Indian mutual funds and ETFs), basis planning, and estate and gift tax considerations before worldwide assets come within the US tax net.
Expatriation & Exit Planning
For US citizens and long-term green card holders giving up their status, the expatriation tax under Section 877A can treat worldwide assets as sold the day before departure. We work through covered expatriate status and the steps that manage the charge, well ahead of the date.
Residency Planning & Cross-Border Mobility
US tax residency can turn on how many days are spent in the country, and people cross into it without meaning to. We advise on managing residency status, including the substantial presence day-count, the closer connection position, the treaty tie-breaker, and the timing of a residency that starts or ends mid-year.
International Wealth & Business Transition
International relocation frequently affects both personal wealth and business interests. We advise entrepreneurs, business owners and family offices on aligning ownership, succession and investment structures with their evolving international footprint.
How We Work
This work is built around timing, because the useful steps sit before US residency begins or before status is given up. We plan the move in both directions and keep residency, ownership and business interests on one timeline, partner-led from the first conversation. We keep any US filing obligations aligned with the overall plan and coordinated with your return preparers.