Tax

Cross-border tax strategy for individuals and families: tax residence, double tax treaties, and pre-immigration or expatriation planning tailored to your circumstances.

BLOQUES DE SERVICIO

Tax Structuring for Wealth Planning

Advising on the tax architecture for each step of the wealth and succession strategy.

Tax structuring of contributions, gifts, spin-offs, and other planning steps under tax-neutrality rules and other applicable regulations.
Quantifying the tax effect of each alternative and comparing it with the current structure.
Implementing holding companies and other vehicles in jurisdictions aligned with applicable tax treaties.

International Tax Planning and Tax Residence

Supporting individuals and families with tax obligations in more than one country: the United States, Mexico, Colombia, and others.

Using tax treaties and foreign tax credits to prevent double taxation.
Advising on exposure to foreign tax transparency regimes (CFC/ECE, GILTI, Subpart F, PFIC).
Analyzing the current and anticipated tax residence of the owner and heirs, and its effect on succession.

Pre-Immigration, Expatriation, and Voluntary Disclosure Planning

Tax strategy for individuals who change their residence or regularize their tax position.

Pre-immigration and expatriation planning tailored to each individual or family's circumstances.
Assessing the tax effect of voluntary disclosure and the regularization of unreported assets.
Coordinating with regulatory specialists on IRS and DIAN filings resulting from the regularization process.

Cross-Border Succession and Taxation of Foreign Vehicles

Quantifying and planning for inheritance taxes when the assets or heirs cross borders.

Estimating inheritance or gift tax in the heir's jurisdiction (e.g., Spain) and making use of available allowances or credits.
Colombian tax treatment of distributions from private interest foundations, trusts, and other foreign vehicles.
Coordinating the taxation of an inheritance between the originating and destination jurisdictions to prevent double taxation.