International Planning

We frequently advise clients who may have citizenship, residency, family members or asset ownership in more than one jurisdiction, where at least one of those jurisdictions is the United States. This includes

• Families abroad with assets in the United States
• United States families with assets abroad
• Persons with temporary or permanent residency in a jurisdiction other than their nationality
• Persons intending to immigrate to or emigrate from the United States.

In cases where more than one jurisdiction has the right to impose taxes on a client’s income, estate or gift transfers, a variety of bilateral tax treaties may provide some relief from double taxation. However, careful planning is often needed to avoid tax mismatch scenarios, where the relief of a treaty may be ineffective.

The United States operates a robust regime of tax laws governing the treatment of offshore investments and trusts owned or established by United States persons.  Stradling frequently advises US-based clients on the effect of these structures, and the steps needed to maintain compliance with these evolving laws.

Although we work with clients all over the world, Stradling’s attorneys have a special focus on clients with contacts in the US and Japan. Stradling attorneys speak, read, and write Japanese with business level fluency to assist in our cross-border practice.