IWTA Services

​FOREIGN TRUST, ESTATE AND GIFT TAXATION

Selecting and implementing a wealth transfer structure and jurisdiction of situs which is most appropriate to your objectives and needs can be complicated as well as the compliance requirements. We can assist you with determining an appropriate structure that fits your specific circumstances and needs and prepare the required disclosures and tax returns.

PRE-IMMIGRATION & EXPATRIATION PLANNING

The U.S. imposes tax on a worldwide basis.  Tax assessment can apply to income that accrued prior to arrival.  The U.S. gift and estate tax can be substantial and can also apply to foreign nationals living in the U.S.  With proper planning, significant savings can be achieved, such as recognizing gains and completing gifts prior to a move to the U.S.

Termination of U.S. residency also requires careful planning. The tax upon terminating U.S. citizenship or green card holders status can be substantial. If immigration status is terminated an individual will continue to be treated as a U.S. income tax resident if they have not filed the appropriate expatriation tax return to disclose their renunciation to the tax authorities.

We can assist you with planning to become a U.S. taxpayer or giving up U.S. tax residency status and prepare the required tax returns and other disclosures as may be required.

U.S. and Foreign Investments

A substantial part of our work involves assessing and planning for U.S. investments made by non-U.S. persons, foreign investments made by U.S. persons and the acquisition and ownership of U.S. real estate by non-U.S. persons.  We can also prepare the associated tax returns.

PRIVATE INVESTMENT FUND ADMINISTRATION

The U.S. is highly regarded for establishing sophisticated investment structures.  We can assist international families and investors with their private investment funds administration need.  We can provide structuring advice, prepare U.S. tax filings and information returns, assist with establishing accounting policies and procedures, maintain books and records, prepare annual management financial statements, prepare annual investor statements, maintain investor capital accounts and provide company directorship services.

VOLUNTARY DISCLOSURES

The U.S. along with other jurisdictions have committed to greater transparency and financial and tax information sharing.  The U.S. has a long standing policy of offering voluntary disclosure programs and initiatives.  We can help you understand the current programs, procedures and initiatives available and prepare the appropriate filings.

FOREIGN ACCOUNT TAX COMPLIANCE ACT (FATCA)

The Foreign Account Tax Compliance Act (FATCA) has been effective for a number of years.  There is a substantial penalty of 30% for non-compliance.  We can assist with determining an entity’s classification status and filing obligations, obtain a Global International Identification Number and prepare Forms W-8BEN-E and 8966 to ensure compliance.

U.S. Business Activities

The U.S. is the worlds largest economy with vast opportunities. The tax system relevant to a U.S. trade or business is complicated and choosing the right structure to do business in the U.S. is extremely important.  Each state has authority separate of the federal government to impose income, sales, and other excise taxes and duties based on the economic activities of a business within its borders.  Determining if a business has activity sufficient for a state to impose tax is not simple and the penalties for noncompliance can be significant.  We can assist you with determining an appropriate structure, the tax implications and filing requirements associated with your business activities and prepare the required tax returns, forms and disclosures required.