International & Cross-Border Tax
Tax planning for people and companies whose lives and businesses cross borders.
Cross-border tax is among the most demanding areas of practice, and among the most consequential to get wrong. KPLAN Law Group advises foreign nationals investing or relocating to the United States, U.S. persons with assets and family abroad, and companies operating on both sides of the Pacific. Much of our work is with clients connected to Korea and the wider Asia-Pacific region.
Typical matters include pre-immigration tax planning for individuals who will become U.S. residents, structuring inbound investment in U.S. real estate and operating businesses, treaty analysis, the treatment of foreign corporations and trusts under the CFC and PFIC rules, and the increasingly strict foreign asset reporting regime: FBAR, Form 8938, Forms 5471 and 3520, and related filings. Where prior filings were missed, we advise on streamlined and voluntary disclosure options.
This work sits naturally alongside our immigration and estate planning practices. A change in visa status, a green card, or an inheritance from abroad each has a tax dimension, and we plan for them together.
How we help
- Pre-immigration and expatriation tax planning
- Inbound investment structuring and FIRPTA planning
- Treaty analysis and withholding on cross-border payments
- CFC, GILTI, Subpart F, and PFIC analysis for foreign holdings
- Foreign asset reporting: FBAR, Form 8938, Forms 5471, 5472, 3520 and 3520-A
- Streamlined filing procedures and voluntary disclosure