Inbound U.S.
Wealth Planning
For international families, founders, and family offices moving capital, businesses, or themselves into the United States. The structure you arrive with is the one you will be living inside for a generation.
Request a consultationOne U.S. strategy, not seven separate opinions.
Most inbound plans fail in the gaps between advisers. The tax counsel does not see the trust deed. The immigration lawyer does not see the holding company. The corporate lawyer forms a Delaware entity that quietly undoes a foreign trust settled years earlier.
We work as the coordinating counsel for the whole U.S. position: tax, trusts, entities, real estate, asset protection, immigration, and litigation risk decided together, in the order they have to be decided, and documented so that each piece supports the others.
That coordination is the work. The individual instruments — a Delaware LLC, a South Dakota trust, an EB-5 or E-2 filing — are ordinary. Sequencing them correctly, before a residency start date or a funding round fixes the position, is not.
Nine months before the move.
A family sells an operating business abroad, plans to relocate two of three children to the United States, and intends to deploy part of the proceeds into U.S. venture and real estate.
The work: pre-residency tax positioning, a domestic trust to hold the non-U.S. assets, a holding structure for the U.S. investments, and an immigration route that does not conflict with either.
Families and firms arriving with something already built.
The common thread is complexity that crosses at least two legal systems.
International families
Multi-jurisdictional families with U.S.-resident or U.S.-bound members, existing foreign trusts, and assets that were never structured with U.S. rules in mind.
Founders and entrepreneurs
Operators relocating a company, redomiciling to Delaware, or raising from U.S. investors, where personal and corporate structuring have to move together.
Family offices
Single and multi-family offices establishing a U.S. platform: investment vehicles, governance, reporting lines, and a counsel of record for U.S. matters.
Investors and allocators
Private investors entering U.S. venture, credit, and real estate, who need the ownership chain and treaty position settled before capital is committed.
Non-resident owners of U.S. assets
Non-domiciliaries holding U.S. real property, brokerage accounts, or private company interests — often with far more U.S. estate exposure than they expect.
Families already here
Households that arrived without planning and now need the structure repaired: foreign trusts recharacterized, entities cleaned up, reporting brought current.
Most of the value is created before you become a U.S. taxpayer.
Once residency begins, the planning set narrows sharply. The window closes on a date, not on a feeling.
Map the position
Assets, entities, existing trusts, citizenships, and intended U.S. footprint — established as facts before anyone proposes a structure.
Fix the residency date
Income tax residency and estate tax domicile are separate tests on separate timelines. Both are planned around deliberately, not discovered afterwards.
Position assets pre-arrival
Basis, timing of gains, distributions from foreign structures, and which assets should be settled, sold, or restructured while there is still no U.S. taxpayer in the picture.
Build the holding architecture
Trusts, holding companies, and investment vehicles formed in the right order, so that ownership, control, and reporting all line up.
Run it properly
Trustee and director duties, distributions, information reporting, and annual review — the maintenance that keeps a structure defensible years later.
Trusts as the family’s operating framework — not an estate-planning formality.
For an international family, a U.S. trust is rarely about probate. It is the instrument that decides who controls capital, where it is taxed, how far into the future it is protected, and how the next generation participates without owning outright.
The United States has become a destination jurisdiction for exactly this work: modern trust statutes, established courts, and a transparent legal environment. The question is not whether to use a trust, but which state’s law, in which role, holding which assets.
Duration and privacy.
No rule against perpetuities, strong sealing of trust records, no state income tax on trust income, and a mature framework for directed and purpose trusts — the default choice for dynastic holding.
Flexibility and control.
Long permitted trust duration, well-developed private trust company and LLC statutes, and a practical environment for families that want to hold governance closer to home.
Precedent and institutions.
The Court of Chancery, a deep body of fiduciary case law, and the jurisdiction most familiar to institutional trustees, lenders, and counterparties — the choice where predictability matters most.
Situs is a decision, not a habit.
We choose the jurisdiction against the family’s actual facts — residence of beneficiaries, asset types, trustee arrangements, and the foreign tax treatment of the trust — rather than defaulting to one state for every client.
Dynasty trusts
Structures designed to hold family capital across generations without a transfer-tax event at each one, with the duration, distribution standards, and amendment mechanics set for a horizon measured in decades.
Directed trusts
Fiduciary roles unbundled: an administrative trustee in the trust’s home state, an investment direction adviser, and a distribution committee — so the family keeps influence over investments without collapsing the trust’s integrity.
Asset protection trusts
Domestic self-settled and third-party protective trusts, built well in advance of any claim, with funding, solvency, and record-keeping documented to withstand later scrutiny.
Foreign trusts and conversions
Existing offshore structures reviewed against U.S. classification and reporting rules, then retained, migrated, or reconstituted — before a family member’s residency changes their treatment.
Family governance structures
Trust protectors, family councils, investment committees, and written participation rules that give the next generation a defined role and a defined limit.
Multigenerational preservation
Distribution policy, education and enterprise provisions, and succession of fiduciary roles — the terms that determine whether capital survives the second and third transfer.
Formation is easy. Ownership chains are where value is won or lost.
Every U.S. vehicle is formed with the family’s tax position, the investors’ expectations, and the eventual exit already in view.
Delaware corporations
C-corporations for operating businesses and venture-backed companies: charter, share classes, founder terms, and treaty-aware ownership from the first round.
Delaware LLCs
Member-managed and manager-managed vehicles, with operating agreements drafted for cross-border ownership rather than adapted from a domestic template.
Holding company structures
Layered ownership that separates operating risk from family capital, keeps U.S. and non-U.S. assets in the right places, and preserves flexibility for later transfers.
Family investment vehicles
Pooled family partnerships and LLCs for co-investment: capital accounts, governance, admission and exit of family members, and coordination with the trusts above them.
Joint ventures
Co-investment and development JVs with U.S. sponsors — economics, control rights, deadlock, and the tax treatment of a foreign partner’s participation.
Founder and investor planning
Equity held in the right hands from the outset: founder vehicles, family ownership of early equity, and the personal planning that has to happen before, not after, a financing.
Artificial Intelligence
Applied research, model companies, and the IP that sits under them.
Technology
Software and platform businesses redomiciling or raising in the U.S.
Fintech
Payments, lending, and digital-asset businesses inside a regulated perimeter.
Life Sciences
Biotech and pharmaceutical ventures, licensing, and research partnerships.
Manufacturing
Industrial operations, plant investment, and cross-border supply chains.
Real Estate
Commercial and residential holdings, joint ventures, and development.
Venture Capital
Funds, allocators, and private investors deploying into U.S. companies.
We plan the way opposing counsel will read it.
This is where an inbound plan is usually thin. Structures are built for tax and immigration, then tested years later by a creditor, a former partner, a regulator, or a family member — none of whom were in the room when it was drafted.
Our practice includes the litigation side of these matters, and that shapes how we build. Every structure is designed against the arguments that will be made about it: who really controlled it, when it was funded, and what it was for.
The institution around the capital.
A structure lasts only as long as the governance that maintains it.
Family office structuring
Establishing or extending a U.S. platform: the entity that employs staff and holds contracts, its relationship to the family’s trusts and investment vehicles, and the regulatory perimeter it operates within.
Governance frameworks
Decision rights written down — who invests, who distributes, who appoints and removes fiduciaries, and how disagreements are resolved without litigation.
Succession planning
Orderly transfer of control as well as of assets: fiduciary succession, management of the operating business, and provisions that anticipate divorce, incapacity, and death in more than one country.
Wealth transfer strategies
Lifetime and testamentary transfers planned around U.S. gift and estate exposure, foreign tax treatment, and the family’s own view of when a generation should receive.
Cross-border family coordination
Working alongside the family’s counsel and advisers in other jurisdictions so that wills, trusts, matrimonial regimes, and forced-heirship rules do not contradict the U.S. structure.
Multigenerational planning
Preparing the next generation to hold responsibility: defined roles, staged participation, and a documented understanding of what the structure is for.
Two failures we are usually called in to repair.
Planning after the start date.
The family becomes U.S. resident first and structures afterwards. The pre-arrival options — repositioning, settling, realizing — are gone, and what remains is more expensive and less effective.
Good advice that does not add up.
Each adviser is right within their own scope. The trust, the holding company, and the visa were designed independently, and the combination produces tax, reporting, or control outcomes nobody intended.
Frequently asked.
Before U.S. residency begins, and ideally before the decision is final. Several of the most valuable steps are only available while there is no U.S. taxpayer in the structure.
Six to twelve months is comfortable. Shorter timelines are workable; they simply narrow the options.
Sometimes. U.S. rules may classify and tax it differently once a settlor or beneficiary becomes resident, and reporting obligations attach to people who never signed anything.
We review the deed and the facts, then advise whether to retain, migrate, or reconstitute it — a decision best made before residency, not after the first filing season.
For families with U.S.-resident members or substantial U.S. assets, a domestic trust in a modern jurisdiction is often simpler to administer, better understood by counterparties, and cleaner from a reporting standpoint.
It is not automatic. Where the family’s centre of gravity remains outside the United States, an offshore structure may still be the right answer, and we will say so.
We plan the U.S. entry as one matter, including how the immigration route interacts with tax residency, entity ownership, and the trust structure — and we coordinate the filings within that plan.
Where a specialist is required, we bring one in and keep the strategy consistent across both workstreams.
Then the exposure is different, not absent. Non-residents holding U.S. real estate, private company interests, or certain accounts can face U.S. estate tax on a far smaller base than U.S. persons, and withholding rules can materially change returns.
The ownership chain, not the investment itself, usually determines the outcome.
The family’s existing advisers. We act as U.S. counsel of record and coordinate with foreign counsel, accountants, trustees, and the family office rather than replacing them.
Where the family has no U.S. adviser network, we assemble one and stay accountable for how the pieces fit.
Plan the arrival, not the aftermath.
A confidential consultation on your family’s U.S. position — before the structure, the funding, or the residency date is fixed.
Request a consultation