We Saved $20M in Taxes
We advise on US expansion and the subsequent sale of business to a publicly traded company. Prior to working with us, they were not aware that failure to properly plan could result in all of... Read more
What are the benefits of owning no assets? Managing warranty risk.
Same fact pattern above but Allen has recently negotiated and sold one of his operating companies. As part of this deal he was asked to provide personal guarantees with respect to certain warranties that formed... Read more
Can a foreign estate be re-domiciled in the U.S?
The Gates family are a London based family. They made their original wealth from a manufacturing business in Newcastle, which they sold 40 years ago. Today all of their capital is managed directly or indirectly... Read more
We Saved $20M in Taxes
We advise on US expansion and the subsequent sale of business to a publicly traded company. Prior to working with us, they were not aware that failure to properly plan could result in all of...
Read more
Restructuring Holdings of a Client in NY-based Fintech
Reviewing laws in both Australia and the US, and working with the private equity investors and the board to model out alternate valuation and tax scenarios.
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Expansion of a Digital Marketing Platform
Prior to working with us they were not aware that failure to properly structure a US business could result in Australian shareholders paying an effective tax rate of 63% or 15% when the sell a...
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Modeling of IRR for a Sydney-based executive
This involved a consideration of whether the investment should be held in his family trust, a corporation or his superannuation fund and whether those entities should be taxed on a flow through basis in the...
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US Expansion of a Technology Business
The client did not understand that double tax treaties only have limited application. There are only 14 substantive articles in the US Australia treaty and the number of tax issues that require cross border coverage...
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US expansion of online retailer
Nu-wave Products Pty Ltd in an Australian cosmetics company that sells their products through an online platform. Due to a spike in US based sales from with no marketing efforts in the US, they have...
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Expansion of franchise business
Barry Black and Jeremy Jackson operate a successful tanning salon franchise in Australia called Bondi Tans. Barry and Jeremy want to expand their business to the US and plan to see franchises across the west...
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Online Super App
Online Super App is a web and application based gaming business that sells online advertising, in-app tokens and provides a voting platform for customers in the UK, US and Australia. Warren Littlefoot and Mike Baxter...
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Consolidation of Global Operating Structure
Stavros and Marina Rastopholopolis run an digital media company with operations in the US, UK, Singapore, Australia, Canada and India. Operations in each country are housed in local corporate entities with shareholders including a combination...
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Global Market Expansion
Steven, Paul and Bruno are Australian citizens and launched their SaaS company in Australia in 2015. The company has grown internationally and now has clients across Europe, Asia and the US. They received advice in...
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I Do Not Qualify for the Streamlined Domestic and Offshore Procedures what are my other options?
Barry Smyth is a U.K. citizen who has moved to the New York 15 years ago. He was not aware of the need to report interests in foreign companies and trusts on his personal tax...
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Do I qualify for the Domestic Offshore Streamline Procedures?
Kevin Driscoll is a US citizen who has lived on the Gold Coast in Australia since the 80s. He came out on a surfing vacation and never returned to the U.S. During this time he...
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What are the U.S. Classification and Reporting Obligations for U.K. and Guernsey entities?
Mrs Sandra Mills a London based businesswoman who migrated recently to the U.S. to expand her business. She or she is a grantor of a Guernsey Trust that owns a portfolio of non U.S. mutual...
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What are the U.S. Classification and Reporting of Obligations for Indian and Dubai entities?
Mr Aman Reddy, an Indian based businessman migrates to the U.S. from India to live closer to his family. He is a grantor of a Dubai based foundation that owns interests in 3 Indian limited...
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What are the U.S. Classification and Reporting of Obligations for Australian entities?
Ben Ball is an Australian resident entrepreneur. He has structured his business through an Australian discretionary trust, five proprietary limited companies, and one limited liability partnership that are all owed by the corporate trustee of...
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What are the benefits of owning no assets? Managing warranty risk.
Same fact pattern above but Allen has recently negotiated and sold one of his operating companies. As part of this deal he was asked to provide personal guarantees with respect to certain warranties that formed...
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What is the benefit of having an offshore trust as the ultimate owner of a family group?
Consider the same fact pattern, but consider a scenario where the interest in the family limited liability company is owned by an offshore trust, like a Cayman Islands Trust, a Guernsey Trust, or a Cook...
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What are the asset protection benefits of each business operating in separate entities?
Allen is an entrepreneur. He has a number of successful operating businesses in the U.S. and has amassed enough capital to buy low risk income producing assets like real estate and stock in public companies....
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Can a foreign estate be re-domiciled in the U.S?
The Gates family are a London based family. They made their original wealth from a manufacturing business in Newcastle, which they sold 40 years ago. Today all of their capital is managed directly or indirectly...
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When an Indian resident dies with a U.S. beneficiary of his estate what are the risks?
The Singh Family own a consortium of established businesses in India and substantial capital assets in the U.K., Dubai and Singapore. The majority of the non business assets are owned through a discretionary family trust...
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When a U.S. person is a beneficiary of an Australian estate what are the risks?
The Ballantyne Family have an established business in Melbourne, Australia and a family office from which they execute on investments within Australia and Asia. All business and investment matters have always run by the patriarch...
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How are Restricted Stock taxed if they are subject to a 83(b) election?
Consider the same fact pattern again but rather than receiving options Miranda was awarded restricted stock. Miranda engaged a tax expert at the time of being awarded her stock and made a 83(b) election with...
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How are you taxed if ISOs or NQSOs are subject to accelerated vesting?
Consider the same fact pattern as above but shortly after Miranda has moved to the U.S. she is notified that her employer is being acquired and that all of her awards are going to be...
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Which country/ies have the right to tax your employee stock options?
Miranda is a Managing Director and country head of a U.S. multinational financial institution. She has been based in Singapore for the last 10 years. She has recently been appointed to the C Suite and...
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LLC, Utilization of Depreciation and Losses.
The Smith family are an Australian based family office. They are currently looking to invest in the U.S. real estate hedge fund based in Atlanta which requires a 5 year commitment. The hedge fund is...
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How do Family Offices determine whether to invest by way of debt or equity?
The Patel family are a Mumbai based family office. They are regularly given the opportunity to co-invest alongside U.S. based hedge funds in various private equity deals. The family’s holdings are structured out of India,...
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How do family offices optimize foreign tax credits in the U.S.?
The Clark Family are a U.K. based family office. They have an established manufacturing business in the U.K. and Asia that has allowed them to accrue substantial amount of capital outside of the family business. ...
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When no income tax treaty exists, when will the Closer Connection Test override the Substantial Presence Test?
Consider the same fact pattern but rather than John residing in the U.S. on an E2 Visa he is residing in the U.S. on a H1B Visa and rather than being from Australia he is...
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How do you apply the Substantial Presence Test?
John is single and he is currently exploring the possible expansion of his business from Australia into the U.S. He has a leased a home in West Hollywood and sold he home in Australia and...
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