Global Tax Planning 101: How to Build a Cross-Border Tax Strategy That Works
I. The Allure of Global Mobility vs. The Reality of the IRS For the modern investor or business owner, the world has never been smaller. From luxury real estate in Miami to tech subsidiaries in Estonia, international borders are often seen as opportunities rather than obstacles. The United States’ legal protections, transparent markets, and economic […]
U.S. Tax Traps for Non-U.S. Investors: What Foreign Owners Often Learn Too Late
The United States continues to attract foreign investors seeking stability, opportunity, and long-term growth. From Miami luxury real estate to operating businesses and passive investment holdings, the U.S. remains one of the most desirable destinations for international capital. Its legal protections, transparent markets, and economic resilience make it an appealing environment for individuals and families […]
Proposed IRC Section 899: U.S. Strikes Back at Discriminatory Foreign Taxes
On May 22, 2025, the U.S. House of Representatives narrowly passed the “One Big Beautiful Bill Act”, a $3.8 trillion tax reconciliation package. Tucked inside is the proposed Section 899, a powerful new provision targeting what the U.S. considers discriminatory foreign tax practices. While the legislation now moves to the Senate—where changes are likely—the introduction of Section […]
Pre-Immigration Tax Planning: What You Need to Know Before Moving to the United States
If you’re planning to move to the United States, there’s more to think about than booking flights and finding a new home. One of the most important — and most overlooked — parts of the transition is your financial and tax planning. The U.S. taxes its residents on their worldwide income, and it applies complex […]