Death, gifts and trusts are where two tax systems disagree most sharply about what is taxable and when. These guides explain deemed dispositions against estate taxes, how a trust settled in one country is treated in another, and the cross-border planning that keeps an inheritance from being taxed twice.
Estates, Gifts & Trusts — 1 in-depth guide
How Elite Families Manage Cross-Border Inheritance Complexities
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.
Other topics Withholding & Forms, Retirement & Pensions, Residency & Status, Foreign Property, Foreign Tax Credit.
Cross-border situations we are engaged for
Foreign trust's three-way reporting duties separated and assigned
A family with a trust settled abroad and a beneficiary in Canada needed the reporting obligations for the trust, the settlor and the beneficiary separated and correctly assigned between the three parties. We identified which party carried which filing duty and prepared the family for each one ahead of the deadlines.
Cross-border estate distribution's withholding confirmed before payment
An estate paying a distribution to a beneficiary living abroad needed the correct withholding and designation confirmed before the payment was actually made to the beneficiary. We reviewed the distribution's character, confirmed the designation, and set the correct withholding before the funds were released.
Two wills reviewed for gaps and unintended cross-revocation
A family with wills drafted in two different countries needed each will reviewed for whether it inadvertently revoked the other or left certain assets unaddressed between the two instruments. We reviewed both wills together and identified the gap before either instrument was relied upon by the family.
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 runsAll case studies — every published engagement in one place.
Core International & Cross-Border Tax Services
Strategy and compliance for income, assets and families spread across borders.
Industries & Client Types We Serve Worldwide
- Foreign VAT / GST / sales tax registrations
- Marketplace withholding reviews
- Inventory nexus & PE analysis
- Multi-currency books reconciled
- Cross-border revenue sourcing & withholding
- IP structuring with real substance
- Equity for cross-border teams
- U.S. expansion: entity & PE setup
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
- Section 216 rental returns
- FIRPTA withholding recovery
- Section 116 clearance
- Treaty credit optimization
- Transfer pricing documentation (s.247)
- Customs value vs transfer price
- Foreign affiliate reporting (T1134)
- Country-by-country reporting
- Reg 105 & U.S. CWA agreements
- Multi-state & country calendars
- Touring income allocation
- Royalty & image-rights withholding
- Residency analysis before moving
- Employer payroll exposure
- Totalization & social security
- Foreign tax credits
- Treaty access & PPT reviews
- FAPI & surplus computations
- Withholding-efficient routing
- Governance & substance
