Caplin & Drysdale attorneys assist foreign and domestic clients with cross-border income and estate planning with the ability to address complex tax issues ranging from the application of tax treaties to issues related to interests in foreign companies (CFCs/PFICs) and trusts, and from relocation of families to the United States to expatriation from the United States.
Bringing a Foreign Inheritance Into the United States: Caplin & Drysdale attorneys assisted U.S. clients with tax structuring and reporting of receipt of a large ($100 million) bequest from a foreign estate, involving several complex foreign trusts and closely-held investment and operating companies. We minimized potential PFIC and trust "throwback" issues. Planning involved exchange of privately-held investment companies for shares of a publicly-listed foreign investment company and decanting of trust assets into new U.S. domestic trusts, requiring meshing of foreign and U.S. tax and legal principles.
Trust Migration: Caplin & Drysdale attorneys assisted a U.S. client with tax structuring and reporting of migration of $11 million foreign-administered NY law trust holding foreign operating companies through a BVI investment company. Planning involved forensic reconstruction of company history and "check-the-box" liquidation of the investment company to avoid possible PFIC and/or CFC taint.
Working with Stars: Caplin & Drysdale attorneys assisted high-profile foreign athletes and entertainers in determining their U.S. tax positions and in developing strategies to minimize tax burden while maximizing profits through tax efficiency.