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
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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