Pre-Immigration
Tax Planning
There is a window before you become a U.S. taxpayer. Planning within it can shape how U.S. income and estate tax apply to your worldwide wealth.
Request a consultationOwn U.S. property, and only $60,000 is shielded.
That is the entire estate tax exemption a nonresident receives.
As of 2026, a U.S. citizen or permanent resident is exempt on the first $15,000,000. For a nonresident, the figure is $60,000.
Everything above that is exposed to federal estate tax, at rates reaching 40 percent.
Your visa does not decide this.
Domicile is a question of fact, and it is settled without you.
You can hold a temporary visa and still be treated as U.S. domiciled. What counts is presence and intent, not the category stamped in your passport.
Once domicile is established, the U.S. estate tax reaches your worldwide assets. The house abroad. The overseas portfolio. The private company.
Gains you made before arriving are taxed here.
An apartment bought abroad in 1999 for $100,000. A green card in 2021. A sale in 2022 at $1,500,000.
The full $1.4 million gain is taxed by the United States, because he is a U.S. resident when he sells. Depending on the rates that apply and the state he lives in, the combined federal and state tax can exceed $400,000 — on a purchase that had no connection to this country when it was made.
The same principle reaches foreign securities, crypto, private equity, and operating businesses.
The same plan, one year apart.
Delay does not simply narrow the options. It raises the price of the rest.
Almost everything is available.
- Appreciated assets can be repositioned
- Global holdings can be restructured
- Trusts can be funded on favorable terms
- Insurance-based structures can be put in place
- U.S. property can be held through the right vehicle
Most of it has closed.
- Restructuring triggers tax, not relief
- Worldwide income becomes taxable here
- Worldwide assets fall within the estate
- Reporting duties attach, with penalties
- What remains is damage control
Plan the move before the move plans you.
Establish when the line is crossed
Residency and domicile are different tests, on different clocks. Both matter.
Map what is exposed
Which assets the U.S. would reach, and what that would cost as things stand.
Restructure while it is still possible
Trusts, holding structures, and insurance-based planning, put in place in the window that exists.
Coordinate the specialists
Cross-border CPAs, foreign counsel, and trustees, working under one privileged relationship.
Frequently asked.
It may. Domicile for estate tax purposes is not the same thing as immigration status.
It turns on where you actually live and whether you intend to remain. People on temporary visas have been found to be U.S. domiciled, and by the time the question is settled it is too late to change the answer.
Earlier than most people think. Some structures need time to be established and to be respected as genuine.
Planning that begins weeks before arrival is far more constrained than planning that begins a year out.
The best options have narrowed, but the position is rarely hopeless.
What remains depends on your facts, how long you have been here, and what you hold. It is worth an assessment rather than an assumption.
No. That is the misconception this practice exists to correct.
Once residency or domicile attaches, the U.S. reaches worldwide income and worldwide assets. Where the asset sits does not settle the question.
Plan the move before the clock starts.
A confidential consultation on what you hold and what the move would cost you.
Request a consultation