Chung, Malhas & Mantel PPLC’s International tax planning and wealth protection services team assists businesses and international families with worldwide tax planning, wealth management and compliance requirements.
In today’s global marketplace, international businesses and individuals must seek out greater efficiency in their tax planning and compliance, ensuring that they minimize their tax burden in the U.S. while staying in compliance with the relevant reporting requirements of the United States Internal Revenue Service.
We provide our clients with a wide range of tax services, including tax planning in connection with immigration to the U.S., domestic and international mergers, acquisitions and joint ventures; real estate investment/financing and global business structures. Additionally, we counsel families and business owners regarding their personal income, estate, gift and wealth transfer matters.
We provide the following services:
Pre-Immigration Tax Planning
Accelerating Income Prior to Immigrating
- Working with clients to ensure that all the income they are owed is accelerated so as to avoid U.S. tax on that income.
R.C Section 7701
- Check-the-Box elections under I.R.C. Section 7701 allows for certain foreign entities to check the box for U.S. tax purposes, which allows for a stepped up basis on the foreign entities’ assets. foreign owned entities resulting in a stepped up basis in underlying assets
Foreign Corporate Holdings
- Review nonresident alien(s) corporate holdings prior to immigrating to the U.S. to ensure minimizing their exposure to U.S. anti-deferral regimes intended to discourage the deferral of income by U.S. taxpayers
- Ensuring the nonresident alien defers their losses contained within their portfolios, which then can be used to offset their income in the U.S., post immigration.
Real Estate Tax
Real Estate Investments
- Advise International clients on the tax implications of real estate investments in the U.S, as well as any reporting requirements associated with those investments.
Real Estate Transactions
- Advise clients on the tax aspects of real estate transactions, from property acquisitions and sales, to 1031 or “like-kind” exchanges, to structuring condo-hotels, long-term care and senior housing and other ancillary service programs
Special Purpose Vehicles
- Advise on special tax-efficient use of special purpose vehicles such as real estate investment trusts (REITs).
- Advise U.S. taxpayers on acquiring foreign entities and structuring their foreign operations
Establishment of U.S. Entities
- Counsel International clients regarding the establishment of U.S. entities
- Counsel International clients regarding acquisitions of U.S. corporations, partnerships, and business assets by foreign companies and individuals
- Structure international joint ventures and restructure multinational groups
Managers and Executives
- Advise sponsors and managers of U.S. and non U.S. investment funds regarding both domestic and foreign tax issues
- Assist clients with treaty issues, foreign tax credits and withholding taxes
Leases, Licenses and Investments
- Assist clients in cross-border leasing, licensing and investing, whether it be individuals, partnerships, or corporations