Pre-Immigration & Expatriation Planning
The U.S. tax system changes dramatically the day you become — or stop being — a U.S. tax resident. The window to plan is before that day, not after.
Who this is for
Individuals planning to move to the U.S. and become tax residents, and U.S. citizens or long-term green card holders considering renouncing or abandoning their status.
What we handle
Pre-immigration: Planning before U.S. residency begins, while you still have flexibility · Strategies involving asset basis, income timing, and pre-residency gifting · Structuring foreign assets and entities ahead of the residency start date · Expatriation: Covered expatriate analysis and exit-tax (Section 877A) exposure · Pre-expatriation gifting and structuring · Coordination of expatriation with your broader estate plan
Why it matters
Becoming a U.S. tax resident brings your worldwide income and assets into the U.S. tax and disclosure system. Expatriating can trigger a mark-to-market exit tax on your worldwide assets. Both are far more manageable with advance planning — and far more costly without it.
How we help
We model your before-and-after position and build a plan that uses the pre-transition window — the one chance to do this efficiently.