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Service · Cross-Border Wealth Structuring

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.

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The Mandate

One 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.

A Typical Mandate

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.

Who We Act For

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.

The Sequence

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.

01

Map the position

Assets, entities, existing trusts, citizenships, and intended U.S. footprint — established as facts before anyone proposes a structure.

02

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.

03

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.

04

Build the holding architecture

Trusts, holding companies, and investment vehicles formed in the right order, so that ownership, control, and reporting all line up.

05

Run it properly

Trustee and director duties, distributions, information reporting, and annual review — the maintenance that keeps a structure defensible years later.

Trust Planning

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.

South Dakota

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.

Wyoming

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.

Delaware

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.

Selection

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.

01

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.

02

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.

03

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.

04

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.

05

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.

06

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.

U.S. Entities

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.

01

Delaware corporations

C-corporations for operating businesses and venture-backed companies: charter, share classes, founder terms, and treaty-aware ownership from the first round.

02

Delaware LLCs

Member-managed and manager-managed vehicles, with operating agreements drafted for cross-border ownership rather than adapted from a domestic template.

03

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.

04

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.

05

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.

06

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.

Sectors we work in

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.

Litigation Risk & Asset Protection

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.

01
Asset protection planning. Protective structures established in advance of any claim, with the timing and solvency record that makes them defensible rather than merely clever.
02
Liability segregation. Operating risk, investment assets, and family capital held in separate vehicles, so a claim against one does not reach the others.
03
Business-risk analysis. A review of where the family’s exposure actually sits — contracts, guarantees, directorships, regulated activity — before deciding what needs protecting.
04
Litigation exposure mitigation. Choice of law, forum, dispute resolution, and insurance arranged as part of the structure, not bolted on when a dispute arrives.
05
Governance controls. Written authority, minutes, distribution procedure, and separation of roles — the evidence that a structure was respected in practice.
06
Founder protection strategies. Personal exposure of founders and directors addressed alongside the company: indemnities, ownership placement, and separation of personal and corporate risk.
07
Family office risk management. Fiduciary liability, custody and counterparty risk, employee and vendor exposure, and the internal controls a family office is expected to have.
Family Office & Governance

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.

Why It Is Done This Way

Two failures we are usually called in to repair.

Too late

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.

Too fragmented

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.

Questions

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.

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