Tax & planning topics
The rules and mechanisms behind an international structure.
Controlled foreign company (CFC) rules
Understand who can be taxed on foreign-company income before assuming that keeping profits abroad creates a deferral.
Exit taxes & departure planning
Separate personal deemed disposals, company migrations and tax obligations that continue after a move.
Personal tax residence
A usable residence plan accounts for home, family, work and travel under the rules of every relevant country.
Corporate tax residence
Incorporation, management and treaty rules can connect one company to more than one tax system.
Management & control: where is your company tax resident?
Understand the country tests, the decisions that matter and the evidence behind a genuine international management arrangement.
Permanent establishments
Remote staff, premises and contract activity can create obligations outside the company’s home country.
Transfer pricing
Related companies need commercially supportable terms that match the work each business actually performs.
Source of income
The customer’s address and the destination bank account are only two facts in a much larger analysis.
Economic substance
People, authority, assets and activity need to support the legal and tax position you intend to take.
Tax treaties & double-tax relief
Treaties can allocate taxing rights and provide relief, but eligibility and the current wording matter.
Banking due diligence
A coherent onboarding file explains who owns the account, how the money is earned and how the account will be used.
Source of wealth & source of funds
Build a clear record of how wealth was created and how the specific money reaches an account or investment.
Citizenship, residence & tax residence
Choose the right legal status for the life and flexibility you want to build.
Pre-immigration tax planning
Coordinate arrival, departure and major transactions while there is still time to make informed choices.
International asset protection
Build clear ownership, sensible separation and reliable administration around the assets that matter.
International succession & estate planning
Coordinate ownership, inheritance law, tax and practical access across every relevant country.