Residence
Presence days, homes, family, business, centre of vital interests and treaty tie-breakers.
01 · PRACTICE AREA
01Private client tax & cross-border structuring
We begin with each family member’s personal tax position: where residence arises, which countries may tax income and capital, how foreign entities affect the result and what changes on relocation, transaction or succession.
PRIVATE CLIENT TAX
The personal tax position comes before the structure
We do not begin with a company registration or a supposedly low-tax territory. We establish the family facts first and only then model a legally defensible solution.
Compare country tax profiles ↘Personal income
Employment, dividends, interest, investments, capital gains and property.
Structures
Companies, foundations, trusts, CFC rules, management and beneficiary distributions.
Succession
Inheritance, gifts, wills, asset situs and net wealth taxes.
Transparency
CRS, beneficial ownership, source of wealth and consistent documentation.
Implementation
Local opinions, tax residence certificates and a calendar of obligations.
WHEN THIS HELPS
Situations families bring to us
The scope of every project is defined after a confidential discussion of objectives, assets and connected countries.
Family members live in different countries or are considering an international relocation
Income, investments, property and companies connect the family to several tax systems
Tax residence must be documented and the consequences of ownership, a transaction or succession assessed
WHAT WE COORDINATE
A coordinated scope of work
- 01Determination and documentation of personal tax residence
- 02Taxation of employment, dividends, investments, capital gains and property
- 03Succession, gifts, wealth taxes and the tax effect of family decisions
- 04Foreign companies, CFC rules, effective management and international reporting
- 05Formation and restructuring of holdings, foundations and other ownership vehicles
- 06Coordination of local tax advisers and legal opinions
A documented family tax position and ownership structure that can be explained to banks, auditors and tax authorities in every relevant jurisdiction.
FIRST STEP
Discuss your situation confidentially
The first conversation identifies the priority, connected workstreams and the right engagement format.