International Private Wealth Law

We provide comprehensive US legal counsel on tax, legal, and succession issues, alongside our clients' team of advisors and international subject matter experts, that arise when wealth spans multiple jurisdictions and generations. Our clients are involved in numerous industry sectors, including high-profile technology founders, world-famous performers, multi-generational families and their family offices, real estate investors and developers across jurisdictions, and founders of multinational privately held and publicly traded companies.

In close collaboration with local tax and legal advisors in each relevant jurisdiction, we provide tailored and personalized US counsel on a broad range of inbound and outbound cross-border legal and tax issues for individuals and families with ties to the US and one or more other jurisdictions, including:

• Cross-border income and wealth transfer succession planning
• Advice and planning involving foreign and domestic trusts, foreign investment structures, and their US tax characterization, including planning with existing structures that will be characterized as passive foreign investment companies (PFICs) or controlled foreign corporations (CFCs), and planning around those anti-avoidance characterizations for new structures
• Advice and planning involving cross-border philanthropic planning and creation of dual-qualified charitable structures
• Inbound transfers of wealth to the US, whether into business ventures or estate planning structures, or both
• Outbound transfers of wealth from the US
• US advice, planning, regulatory compliance, and reporting obligations for individuals, companies, and trustees
• US income residency considerations for individuals, trusts, and businesses
• Individual estate tax residency
• Classification of non-US structures, including civil law private benefit foundations (stiftungs and anstalts), and usufruct/bare ownership structures for US tax purposes
• Planning for securing consistent succession and marital property rights across jurisdictions
• US exit planning for US citizens and long-term residents
• Application of bilateral income and estate tax treaties

Our holistic approach – shaped by collaboration with each client’s advisory team, our multi-disciplinary expertise, and a trusted network of international tax and succession experts – ensures durable, integrated planning solutions focused on each client’s priorities and values.