Global Mobility Immigration and Tax

Global Mobility, Immigration and Tax

6 Apr 2023

Streamlined Coordinated Services – Immigration and Tax

Transitioning key talent from one country to another presents complex issues for the multinational corporation. Global mobility requires coordination of services between in-house legal, human resources, and other divisions in multiple countries. The typical approach is to hire one of the large immigration firms and the big accounting firms to handle the immigration and tax work, believing this is the best way forward. We have seen too often under this model that the services are not customized and collaborative to the multinational corporation or the employee transitioning to work in a new country.

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Not Over Taxing Gains on Qualified Small Business Stock

QSBS

30 Mar 2023

Not Over Taxing Gains on QSBS (Qualified Small Business Stock)

The exclusion from gain applicable to the sale of qualified small business stock (“QSBS”) is a key benefit in selecting C corporation status for startups and other businesses. QSBS stock allows the noncorporate taxpayer to exclude from gain the greater of $10 million or ten times the taxpayer’s basis in the stock (“QSBS Eligible Exclusion Amount”). Properly excluding this gain from tax is an important tax savings opportunity and significantly increases the noncorporate taxpayer’s return on investment.

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23 Mar 2023

Power of the CRUT and Importance of Correct Tax Reporting to Receive the Desired Benefits

Family offices and private clients (“Clients”) have complicated investment and estate planning structures that require professionals to understand how to handle the needs from legal, accounting, and tax reporting. One of the planning tools frequently implemented for these Clients is a charitable remainder unitrust (“CRUT”). The CRUT allows for the tax-free liquidation of a highly appreciated asset, the tax-free growth of the assets inside the CRUT, with the income building inside the CRUT only being taxed to the extent of distributions to the lifetime beneficiary. This is a powerful tool if the tax reporting occurs correctly. We have noticed a gap between the estate planning and the tax reporting often resulting in phantom income being taxed to the detriment of the beneficiaries.

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16 Mar 2023

Customized Mergers and Acquisitions Due Diligence Services

In the acquisition of a business, it is important the buyer has a clear understanding of the target’s financial, commercial, operational, technical, human capital, and tax condition. Too often, certain parts of the due diligence do not receive the attention required, either because the firm performing the due diligence does not have the necessary background, or there is a lack of coordination among professionals in different fields of expertise. This is a critical opportunity for the buyer to learn of issues with the target as the nonidentification of key issues will have a financial impact down the road for the buyer.

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16 Mar 2023

Tax Preparation for Clients with International Assets and Businesses 

U.S. tax reporting for U.S. persons with businesses or assets outside the U.S. is complex, legal intensive, and there are many traps for the unwary that can carry serious penalties. The tax preparer must understand the forms to prepare, understand the rules as the tax preparation software has not caught up to the complexity of the reporting, and be prepared to take legal positions to obtain the best result for the client. Too often, tax preparers do not have the necessary background to handle the tax reporting for international clients.

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25 Feb 2023

Customized Tax Preparation as Key Strategy for Tax Savings

We routinely see mistakes in the reporting on tax returns provided by the previous tax preparer and the tax planning strategy provided in a legal memorandum, thus missing the tax savings desired. This can result for many reasons such as the client did not provide the memorandum to the tax preparer, the tax preparer did not understand how to report the tax strategy, practically the tax strategy did not work, or that the tax preparer and attorney advisor did not work together collaboratively. Our approach is to not make it the responsibility of the client to ensure the tax strategy is carried out, but to have advisors with legal backgrounds at the table with the tax preparer collaborating together to ensure the desired result is carried out.

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Praestans | Customized Fund Administration

24 Feb 2023

Customized Fund Administration Services

Fund managers frequently experience a lack of coordination between their legal, accounting, and fund administration services.  Often fund managers receive a preset of services that are not customized to their fund, are faced with minimum service prices, and experience long response times from each set of professionals.  We provide cohesive services amongst professionals customized to the needs of our clients.  This provides our clients with the best services that are tailored to our clients' needs.

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Business Tax Planning, ROI, tax planning

16 Jan 2026

U.S. FATCA Model 2 Reporting Obligations for New Fund Managers

For fund managers operating under Model 2 IGAs, U.S. FATCA compliance requires direct engagement with the IRS, precise reporting, and ongoing oversight. Clear processes and reliable support can make the difference between routine compliance and unnecessary risk.

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Business Tax Planning, ROI, tax planning

20 Nov 2025

Measuring ROI: Tools for Profitability and Strategic Growth

Understanding ROI gives business leaders a clear view of which initiatives are creating value and which need reevaluation. With the right metrics, companies can make sharper, more confident decisions that accelerate growth and profitability.

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Business Tax Planning, tax planning

6 Nov 2025

The Role of Financial Forecasting in Business Planning and Decision-Making

Financial forecasting plays a critical role in helping businesses anticipate cash flow, assess risks, and plan strategically. By using pro forma statements and accurate projections, companies can make informed financial decisions that support stability and long-term growth.

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Business Tax Planning, tax planning

20 Aug 2025

Profits Interest in Tiered Partnerships

In structuring a private equity fund or other tiered partnership arrangement, care must be taken to ensure the safe harbor for profits interest received for services is preserved. It is important in the issuance of profits interest to carefully document and substantiate capital account book-ups to protect against IRS contest that the interest is a capital interest.

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tax planning

7 Aug 2025

Rollover of Hedge Fund Interest Fails IRA Rules: Estate of Caan Offers a Warning on Nontraditional Assets

When an IRA holds a nontraditional asset such as an interest in a private hedge fund, the Taxpayer must be extremely careful to provide the annual value for that interest to the custodian and to follow the rules in rolling that nontraditional asset to a new IRA. Failing to do so can result in significant tax implications.

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C-Corporation, M&A, tax planning

31 Jul 2025

Selling a Business: Plan Carefully for Assumed Liabilities and Deferred Compensation

In determining the sales price in an acquisition, the seller must determine how assumed liabilities will be treated and either adjust the sales price accordingly or plan to allow the deduction to occur prior to sale.

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avoid double taxation, FATCA compliance for U.S. citizens, tax filing, tax for U.S. citizens and U.S. tax residents

14 Mar 2024

U.S. Taxation of U.S. Citizens and U.S. Tax Residents Residing Overseas – Foreign Bank Accounts

The government does not annually tax wealth.  However, the IRS wants to know about funds U.S. Persons have in foreign bank accounts.  There are now two different reporting requirements for foreign bank accounts, the Foreign Bank Account Report (“FBAR”) and the individual reporting requirement under the Foreign Account Tax Compliance Act (“FATCA”).

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avoid double taxation, tax filing, tax for U.S. citizens and U.S. tax residents

29 Feb 2024

U.S. Taxation of U.S. Citizens and U.S. Tax Residents Residing Overseas – Mitigation of Double Taxation

There are two methods that a U.S. Person living abroad can use to reduce their U.S. tax liability.  The two methods are the Foreign Earned Income Exclusion (“FEIE”) and the Foreign Tax Credit (“FTC”).  Even if one of these methods were to eliminate the U.S. Person’s U.S. tax liability, the U.S. Person is still required to file their U.S. tax return if their income exceeds the filing thresholds for the tax year. 

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tax filing, tax for U.S. citizens and U.S. tax residents

15 Feb 2024

U.S. Taxation of U.S. Citizens and U.S. Tax Residents Residing Overseas

U.S. citizens and U.S. tax residents (“U.S. Persons”) are taxed in the United States on their worldwide income no matter where in the world they reside. The U.S. taxes based on citizenship, which is different than almost all other countries in the world that tax based on residence. This often catches U.S. Persons who have never lived in the U.S. or have lived abroad for a number years by surprise. Any U.S. Person living abroad with income for tax year 2023 above the following thresholds must file a U.S. tax return:

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tax filing

1 Feb 2024

Tax Filings for the International Executive

Recently we were transitioning to take over the tax filing for an executive who was a U.S. tax resident because he had a green card but resided outside the U.S.  This executive has considerable income and the country that he resided in also taxed at higher rates than the U.S. federal income tax rates. Our review of the executive’s tax return not only found there were informational reporting errors, but that the income of the executive had been over reported by more than $160,000

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PFIC, PFIC Testing

18 May 2023

PFIC Testing for Foreign Portfolio Companies

Funds with U.S. investors, U.S. family offices, and individual U.S. investors (collectively, “U.S. Investors”) must be cognizant of whether their foreign investment in private companies is an investment in a passive foreign investment company (“PFIC”). Typically, a foreign portfolio company would be classified as a corporation for U.S. income tax purposes unless an election was made to have it taxed otherwise. The issue with PFICs is that unless certain elections are made, distributions from a PFIC may be subject to an excess distribution regime resulting in a punitive tax and interest charge. In certain bad circumstances, the punitive tax and interest charge can be the amount of the distribution.

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