Cross-border tax problems fall into a small number of shapes, whatever the jurisdictions involved. The groupings below describe them. Advisers are also instructed on domestic tax matters within their own jurisdiction. The matters named are illustrations, not a closed list.
Residence changes, and the tax consequences that follow in both the country departed and the country arrived in. The planning window closes when the move happens rather than when it is announced, which is why these matters are usually worth raising early.
Illustrative: residency start and end dates and treaty tie-breakers; planning available before residence begins, including basis and entity classification steps; expatriation and exit charges, including the US regime under §877A; the treatment of pensions, employment income and existing holdings on arrival or departure; and social security and employer obligations where work follows the person.
Where the owner, the asset and the beneficiaries are not all in one place, more than one system usually has a claim, and the structures built for one rarely behave as expected in another.
Illustrative: holding, financing and succession structures; trusts and foundations and their treatment in the countries that matter; estate, gift and situs exposure, including the far lower US threshold applying to non-domiciled individuals; real estate held cross-border; wealth and net-worth taxes; and investment vehicles that are efficient in one jurisdiction and punitive in another, such as PFIC exposure within European funds held by US persons.
Corporate groups face the same question repeatedly: where profit arises, which system may tax it, and what must be documented to support the answer.
Illustrative: transfer pricing policy, documentation and benchmarking; the Pillar Two minimum-tax regime and the domestic obligations that survive a centralised group filing; permanent establishment and treaty entitlement; the European direct-tax directives, including ATAD and DAC6; holding, financing and principal structures, including the Swiss elements of them; reorganisations, migrations and intra-group transfers; and the tax dimension of transactions and due diligence.
Obligations frequently attach before any tax is due, and the cost of discovering them late is usually larger than the tax itself.
Illustrative: US reporting including §5472, FIRPTA withholding, FBAR and FATCA; the common reporting standard and exchange of information; disclosure regimes and the correction of past positions; and dealings with the authorities where a position is questioned.
These groupings are how cross-border questions tend to arrive, not a service list. Where a matter falls outside what any adviser in the network covers, that is said at the outset and a trusted local firm is instructed.
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That is said at the outset rather than answered at a distance. A trusted local firm in the relevant jurisdiction is instructed, and its analysis is coordinated into the same written position.
More often than people expect. The United States taxes non-residents on income effectively connected with a US trade or business and on certain US-source income, and applies a separate estate and gift regime to US-situs assets held by non-domiciled individuals — with a far lower exempt threshold than applies to US persons.
Reporting obligations frequently attach before any tax is due, including §5472 for foreign-owned US disregarded entities and FIRPTA withholding on dispositions of US real property.
The period before the new residence begins. Steps that are straightforward beforehand — basis planning, entity classification elections, distributions from existing structures — become materially harder or impossible once residence has commenced. The window closes when the move happens, not when it is announced.
Vodexis admits established practices with genuine domestic depth in their jurisdiction and a working command of cross-border matters. Enquiries from firms go to chris@vodexis.com.
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