Pre-Immigration Tax Planning

A key component of our tax practice at Salcedo Attorneys at Law P.A. is to provide advice to non-domiciled taxpayers.

Our counsel guarantees an individual compliance with U.S. tax legislation during a period of non-tax residency, and achieves an efficient, and organized transition to becoming a U.S. tax resident.

Our services include:

● Performing an assessment of tax residency on the basis of the various applicable tax residency tests under U.S. legislation and applicable tax treaties.
● Delivering a diagnosis of applicability of potential exceptions to tax residency under applicable U.S. legislation and tax treaties in force.
● Coordination of applications which avoid dual tax residency under applicable tax treaties in force (treaty tie-breaker applications).
● Providing advice and recommendations to various applicable income taxes, capital gains taxes, excise taxes, withholding taxes and transfer taxes applicable to nonresidents and U.S. persons.
● Advising on compliance with anti-deferral regimes under applicable controlled foreign corporations, global intangible low-taxed income, and passive foreign investment companies rules applicable to U.S. resident aliens.
● Coordinating compliance with applicable tax returns and formalities during the period of non-tax residency and the transition as a tax resident.
● Adjusting cost basis of assets to current fair market value prior to becoming a U.S. tax resident.
● Counseling on alternatives to minimize tax compliance obligations applicable to foreign entities, and foreign bank accounts owned by taxpayers under U.S. and foreign tax rules and regulations.

We pledge to provide our best advice, while always safeguarding our client’s best interests.