What is international tax structuring?

International tax structuring is the legal design of corporate and wealth architectures that enable individuals and businesses operating across multiple jurisdictions to meet their tax obligations efficiently, leveraging applicable treaties and regimes.

Who needs international tax advisory services?

Individuals with tax residency in one country and assets, income, or family in another; entrepreneurs with cross-border operations; heirs of international estates; and families planning relocations.

What is FATCA and how does it affect non-US residents?

FATCA (Foreign Account Tax Compliance Act) requires foreign financial institutions to report accounts held by US persons to the IRS. It affects US citizens and residents with accounts abroad, and entities with US beneficial owners.

International Tax Structuring

Leveraging our international exposure, we provide a practical and unique approach, providing a succinct analysis of the tax structuring implications and efficiencies of cross-border business.

Business financing structuring.
Taxation of foreign businesses.
Permanent establishments.
Real estate investment structuring.
Capital gains on sale of shares.
Tax efficiencies for branches, subsidiaries and holdings.
Advice regarding controlled foreign companies (CFC) rules.
Tax planning covering different tax jurisdictions.
Use of double tax treaties.
Selection of tax-efficient legal structures for foreign companies.

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Advisory

International Tax
Structuring

Cross-border tax analysis, treaty optimization, and compliance architecture for international families, investors, and businesses.

30+ Jurisdictions

20+ Years Experience

3 Global Offices

The Tax Landscape

01 Tax Residency Where you live determines how you are taxed globally.

02 Treaty Networks Bilateral agreements that reduce withholding and prevent double taxation.

03 Substance & Compliance CRS, FATCA, BEPS, and economic substance rules across jurisdictions.

04 CFC Rules Controlled foreign company regimes that attribute income to shareholders.

Our Approach Tax structuring is not about minimization.
It is about alignment.

We map your global tax footprint first. Before recommending any structure, we audit residency status, income sources, asset locations, citizenship ties, and applicable treaty networks. The map precedes the route.

Then we design for resilience, not just efficiency. Aggressive structures collapse under regulatory pressure. We build architectures that remain defensible as BEPS evolves, treaties are renegotiated, and substance requirements tighten.

We coordinate across jurisdictions and advisors. International tax planning fails when advisors work in silos. We act as the central node — integrating local counsel, accountants, and compliance teams into a single coherent strategy.

What This Practice Covers

01 Tax Residency Analysis Tie-breaker analysis, domicile assessment, and residency migration planning across multiple jurisdictions.

02 Treaty Optimization Withholding rate reduction, treaty eligibility, and LOB clause navigation for cross-border income flows.

03 Holding & IP Structures Holding company placement, intellectual property routing, and intercompany pricing frameworks.

04 Real Estate Taxation Cross-border real estate investment structuring, capital gains optimization, and withholding management.

05 CFC & PE Exposure Controlled foreign company analysis, permanent establishment risk assessment, and branch vs. subsidiary decisions.

06 Compliance & Reporting FATCA, CRS, FBAR, Form 5471, country-by-country reporting, and beneficial ownership disclosure coordination.

Who This Serves

International Entrepreneurs Operating across borders with income in multiple jurisdictions.

Expatriates & Relocating Families Navigating tax residency transitions and exit tax exposure.

Cross-Border Investors Portfolio and direct investments with multi-jurisdictional tax implications.

Family Offices & UHNWI Complex multi-entity structures requiring coordinated global tax strategy.

The goal is not to pay less tax.
It is to pay the right tax, in the right place.

Related Advisory Services

01 Wealth Structuring Estate planning, trust design, and cross-border succession strategies. 02 Asset Protection Multi-layered frameworks to shield wealth from creditors and risk. 03 Incorporations Entity formation across 7 jurisdictions with full compliance support.

Map your tax exposure. Schedule a confidential consultation to evaluate your cross-border tax position and explore structuring strategies aligned with your goals. SCHEDULE CONSULTATION