Who We ServeInternational Individuals & Families

International Individuals & Families

Cross-border wealth planning for global families seeking U.S. investment access, pre-immigration optimization, or efficient structures for transitioning foreign capital into the American financial ecosystem.

40%U.S. Estate Tax on NRAs
$60KNRA Estate Tax Exemption
15%FIRPTA Withholding Rate
Common Scenarios
  • Pre-immigration planning before green card
  • Foreign Grantor Trusts transitioning status
  • NRAs investing in U.S. private markets
  • Global families with U.S.-based children
  • Entrepreneurs relocating to the United States
  • Wealth protection from home country instability

The Pre-Immigration Planning Window

The period immediately before U.S. tax residency begins is the single most valuable planning opportunity for international families. Strategies available during this window become unavailable—or significantly less effective—once U.S. residency commences.

Unlimited Gifting Window

Before establishing U.S. tax residency, transfers to irrevocable trusts and certain entities can often be completed without triggering U.S. gift tax—a window that closes permanently upon immigration.

Step-Up in Basis

Assets held before U.S. tax residency may qualify for a fresh-start step-up in cost basis, dramatically reducing capital gains exposure on future dispositions within U.S.-compliant structures.

Trust Structure Selection

The decision to establish a foreign vs. domestic trust, its grantor status, and beneficiary structure must be finalized before U.S. residency begins—restructuring after residency triggers punitive tax consequences.

The International Wealth Challenge

Minimal NRA Estate Tax Exemption

Non-Resident Aliens have only a $60,000 U.S. estate tax exemption vs. $15M for citizens and residents (permanent)—creating substantial exposure for foreign nationals with U.S. situs assets.

FIRPTA Withholding

15% withholding on dispositions of U.S. real property interests by foreign nationals creates significant friction for international investors seeking U.S. real estate exposure.

Trust Status Transitions

Foreign Grantor Trusts converting to Non-Grantor status upon immigration trigger throwback tax issues and require careful advance planning to avoid punitive tax consequences.

PFIC & CFC Reporting

Foreign investment structures create complex U.S. reporting obligations with punitive tax regimes—including mark-to-market elections and excess distribution rules under PFIC and Subpart F income under CFC rules.

Pre-Immigration Timing

The window before U.S. tax residency begins is the most critical—and most time-sensitive—planning period. Structures established after residency begins lose key tax benefits.

Home Country Instability

Political risk, currency devaluation, or capital controls in the home country create urgency for international wealth diversification and U.S.-based asset protection strategies.

International Tax Framework

FIRPTA

Foreign Investment in Real Property Tax Act

15% withholding applies to NRA dispositions of U.S. real property interests. Insurance-based structures provide compliant real estate exposure while eliminating FIRPTA withholding friction.

ECI

Effectively Connected Income

U.S.-source income attributable to a U.S. trade or business is taxed at graduated U.S. income tax rates rather than the standard 30% flat NRA withholding rate.

Throwback Tax

Accumulation Distribution Rules

Undistributed net income held in foreign non-grantor trusts is subject to a punitive interest charge upon eventual distribution—making proactive trust transition planning critical before immigration.

Substantial Presence

Substantial Presence Test

The 183-day weighted formula that triggers U.S. tax resident status. Once satisfied, worldwide income becomes subject to U.S. taxation—making the pre-residency planning window time-critical.

Policy Domicile Considerations

01

U.S. Domiciled Policy

02

Offshore Carrier, U.S. Contract

03

Purely Offshore Structure

Key Structures for International Families

Pre-Immigration Structure

Foreign Grantor Trust (FGT)

Unlimited transfers without gift tax, income accumulation benefits, and maximum flexibility before U.S. tax residency commences.

Post-Immigration Management

FGT to Non-Grantor Trust Transition

Addresses throwback tax and ECI concerns during trust status conversion following the establishment of U.S. tax residency.

Estate Planning Structure

International ILIT

Removes assets from taxable estates, facilitates insurance-based wealth transfer, and provides efficient cross-border death benefit delivery.

NRA Investment Solution

Insurance-Based Investment Access

Provides private market exposure within a compliant structure that avoids FIRPTA, minimizes U.S. estate tax exposure, and simplifies reporting.

Strategic Results

U.S. Market Access

Compliant exposure to American private markets

Jurisdictional Diversification

Strategic use of multiple legal systems

Estate Tax Efficiency

Structures that minimize U.S. estate tax exposure

Privacy Protection

Confidential ownership structures

Tax-Efficient Growth

Deferred compounding within compliant wrappers

Multi-Generational Transfer

Cross-border dynasty and legacy structures

Liquidity Access

Policy loans and withdrawals without repatriation friction

Simplified Compliance

Consolidated reporting minimizes cross-border obligations

Cross-Border Planning for Your Family

International wealth planning requires specialized expertise at the intersection of U.S. and foreign tax law. A confidential conversation can help determine the optimal approach for your family's unique circumstances.

Disclosures and Important Considerations

  1. This material is provided for informational and educational purposes only and should not be construed as legal, tax, investment, or accounting advice. You should consult your own qualified advisors regarding your specific situation. The authors and affiliated entities are not engaged in rendering legal, tax, or actuarial services.
  2. This material does not constitute an offer to sell or the solicitation of an offer to purchase any security, investment product, or insurance policy. Any such offer may only be made through formal offering documents and in accordance with applicable law.
  3. Certain strategies and structures discussed herein, including private placement life insurance (PPLI), private placement variable annuities (PPVA), and insurance-dedicated funds (IDFs), are intended only for qualified purchasers, accredited investors, or insurance company separate accounts, as defined under applicable securities laws.
  4. Tax treatment depends on proper structuring, ongoing compliance, and current law, all of which are subject to change. Policy design, ownership structure, jurisdiction, and ongoing administration may materially impact outcomes. Policy loans, withdrawals, and trust ownership arrangements may affect tax results and should be reviewed with qualified advisors.
  5. Private placement life insurance (PPLI) and private placement variable annuities (PPVA) are complex, long-term insurance products that combine insurance coverage with investment options. Policy values will fluctuate based on investment performance, fees, and charges. Loans and withdrawals may reduce policy value and death benefits and may have tax consequences if not properly structured. Life insurance policies are subject to underwriting, carrier approval, and ongoing policy requirements, and if a policy lapses, is surrendered, or fails to meet applicable tax law requirements, adverse tax consequences may result.
  6. Any financial illustrations, projections, or hypothetical examples are for informational purposes only and are not intended to predict or project actual results. These examples are based on assumptions that may not reflect actual market conditions or client experience. Actual results will vary and are not guaranteed.
  7. References to historical performance, target returns, or asset class characteristics are provided for general informational purposes only and are not indicative of future results. Target returns are hypothetical in nature, are not guarantees, and may not be achieved. Investments involve risk, including the possible loss of principal.
  8. Investments in private markets, including private equity and fund-of-funds structures, are speculative, involve a high degree of risk, and are subject to limited liquidity. Such investments may involve multiple layers of fees and expenses, use of leverage, and exposure to underlying managers whose strategies may be complex and difficult to evaluate.
  9. Fees, expenses, and charges at both the insurance policy level and underlying investment level may reduce overall returns. Certain illustrations may not reflect all fees, including insurance-related charges, advisory fees, or underlying manager expenses. Tax laws, regulations, and interpretations may change and could impact the comparative results or benefits described herein.
  10. No representation or warranty is made as to the accuracy or completeness of the information contained herein. All statements and opinions are subject to change without notice and are not guaranteed. Investment decisions should be based on an individual’s specific objectives, time horizon, and risk tolerance. Diversification does not ensure a profit or protect against loss. Any investment decision should be made only after reviewing the applicable offering memorandum and related documents.