Insurance Solutions for the Global Client and World Citizens
We are able to assist non-US clients in matters such as:
- Pre-immigration planning to protect foreign assets from US income tax.
- Providing liquidity for holdings in countries with estate and/or inheritance taxes
- Combining strong dollar-denominated asset classes and tax-neutral jurisdictions to protect wealth
- Solving the inequality problems caused by forced heirships and succession planning
- Estate planning for US real property assets, particularly valuable personal residences. Non-US citizens do not benefit from the same estate exclusion amounts as US citizens.
- Foreign non-grantor trusts that must confront issues of distributable net income (“DNI”) and undistributed net income (“UNI”) because such trusts have US persons as beneficiaries.
- Issues relating to Passive Foreign Investment Corporations (“PFICs”) and Controlled Foreign Corporations (“CFCs”); and
- Techniques to avoid Effectively Connected Income (“ECI”) and Branch Profits Tax (“BPT”) on certain partnership investments.
Clients who are citizens of other countries and reside in the US or acquire certain US property must deal with issues of US taxation, in particular income and transfer taxes. Because the US taxes worldwide income and assets, individuals may encounter unexpected and burdensome tax issues.
* National Madison Group, Inc. does not provide tax or legal advice. Any discussion of taxes is for general information purposes only, it should not be construed as legal, tax or accounting advice and does not purport to be complete or cover every situation. Please consult your tax advisor or attorney for such guidance.