Estates, Gifts & Trusts — 1 in-depth guide
How Elite Families Manage Cross-Border Inheritance Complexit
How elite families manage cross-border inheritance complexities — the mechanism, the paperwork sequence, and the errors we correct most often, with every variant of the question answered in one guide.
Cross-border situations we are engaged for
A Family Trust Abroad With Reporting on Both Sides
A trust settled in one country and a beneficiary living in another produces reporting for the trust, the settlor and the beneficiary, on different forms and different dates. The engagement maps who files what before anything is prepared.
Read how this one runsPaying a Beneficiary Who Lives Abroad
Distributions to a non-resident beneficiary carry withholding and a designation that decides its rate. Getting the designation right before the payment avoids recovering the difference through a return afterwards.
Read how this one runsTwo Wills, Two Jurisdictions, One Estate
A will drawn for one country can revoke another or fail to reach assets held abroad. The review checks how each instrument interacts with the other and where probate will actually be required.
Read how this one runsDocumentation Built to the US Standard
The US requirements differ from the OECD-aligned ones in what has to exist at the time of filing, and a file prepared for one regime can leave the other unprotected. The engagement builds to whichever governs.
Read how this one runsNever Filed a US Return — and Only Just Found Out
Born in the United States, left as an infant, and told by a bank that the returns were owed all along. The work is sequencing: establish which years are actually open, choose the catch-up route on the facts rather than filing quietly, and claim the exclusions and credits that were never taken.
Read how this one runsAn Executor Administering Across Two Systems
An executor can be personally liable for what is assessed after a distribution, and the clearance that protects them is obtained rather than assumed. The engagement sequences the filings so the distribution is safe when it happens.
Read how this one runsThe Deemed Sale That Happens on Death
Canada treats most capital property as sold at fair market value on death, so a terminal return can carry tax on gains nobody realised. Valuations and the order of the returns are what decide the figure.
Read how this one runsWithholding Reduced by the Right Article
Dividends, interest and royalties each have their own article and their own rate, and the payer applies whichever it is satisfied of. Establishing entitlement before payment is what secures the lower rate at source.
Read how this one runsAll case studies — every published engagement in one place.
Core International & Cross-Border Tax Services
International Tax Planning & Advisory
Strategy and compliance for income, assets and families spread across borders.
U.S. & Cross-Border Tax Returns
Expat & Emigration Tax
Non-Resident Canadian Tax
Transfer Pricing & BEPS
Tax Treaties & Withholding
Cross-Border Estates & Trusts
Global Investments & Reporting
Cross-Border Corporate Tax
India Tax for NRIs & Returning Residents
Canadian Tax with a Foreign Element
UAE Tax for Expats & Their Home Country
Industries & Client Types We Serve Worldwide
Global E-commerce & Marketplaces
- Foreign VAT / GST / sales tax registrations
- Marketplace withholding reviews
- Inventory nexus & PE analysis
- Multi-currency books reconciled
Technology & SaaS
- Cross-border revenue sourcing & withholding
- IP structuring with real substance
- Equity for cross-border teams
- U.S. expansion: entity & PE setup
Professional Services Firms
Firms and partners working across borders meet Regulation 105 withholding, PE risk on long engagements and per-country payroll for travelling staff.
A partnership is taxed in the hands of its partners, so one engagement abroad can reach every partner's personal return. The order matters: the waiver is applied for before the invoice, the presence is tracked before it becomes an establishment, and the payroll is registered before the first day worked in the other country.
- Reg 105 / 102 waivers
- Permanent establishment risk
- Partner mobility planning
- Cross-border withholding recovery
Cross-Border Real Estate
- Section 216 rental returns
- FIRPTA withholding recovery
- Section 116 clearance
- Treaty credit optimization
Importers, Exporters & Manufacturers
- Transfer pricing documentation (s.247)
- Customs value vs transfer price
- Foreign affiliate reporting (T1134)
- Country-by-country reporting
Athletes, Artists & Entertainers
- Reg 105 & U.S. CWA agreements
- Multi-state & country calendars
- Touring income allocation
- Royalty & image-rights withholding
Remote Workers & Digital Nomads
- Residency analysis before moving
- Employer payroll exposure
- Totalization & social security
- Foreign tax credits
Investment Funds & Holding Companies
- Treaty access & PPT reviews
- FAPI & surplus computations
- Withholding-efficient routing
- Governance & substance
