US Cross-Border Tax.
US-side cross-border tax planning across ECI, FDAP, PE, CFC, and PFIC regimes, plus estate, trust, and pre-immigration positioning for globally mobile clients.
US Effectively Connected Income (ECI) analysis
Whether foreign-source income is treated as ECI and taxed on a net basis at graduated US rates.
US Fixed Determinable Annual Periodic (FDAP) Income analysis
Identification, withholding, and treaty positioning for US-source FDAP paid to non-US persons.
Permanent Establishment & Dependent Agent determination
Treaty-based PE analysis, dependent agent exposure, and threshold management for foreign businesses.
Controlled Foreign Corporation rules, Subpart F & Net CFC Tested Income
CFC determination, Subpart F inclusions, GILTI / Net CFC Tested Income, and high-tax exception planning.
Passive Foreign Investment Company (PFIC) rules
PFIC identification, QEF and mark-to-market elections, and the excess-distribution regime for offshore funds.
Income tax planning for US persons living abroad
Foreign Earned Income Exclusion, Foreign Tax Credit positioning, and treaty-based filing for citizens and green-card holders.
Estate & gift tax planning for US and non-US domiciled families
Domicile analysis, lifetime exemption planning, and US-situs asset structuring for mixed-nationality families.
US trust taxation
Domestic vs. foreign trust classification, throwback rules, grantor and non-grantor planning, beneficiary reporting.
Exit tax planning
Section 877A expatriation analysis for covered expatriates, mark-to-market and deferred-compensation planning.
Pre-immigration tax planning
Step-up planning, basis cleanup, and entity restructuring before establishing US tax residency.
Continue across Cross-Border Tax
02 / 03Panama Cross-Border Tax
Panama-side cross-border tax planning under the territorial principle: source-of-income analysis, pre-arrival positioning, holding architecture, and special regimes.
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03 / 03Canada Cross-Border Tax
Canada-side cross-border tax planning: residency cessation, deemed-disposition planning, FAPI, trust taxation, and the information-reporting regime.
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In closing
Let’s talk.
A single conversation usually clarifies more than a month of research. We engage on a value basis, and every introduction begins with a direct, confidential exchange.
We advise on
- 01Cross-Border Tax
- 02International Corporate Advisory
- 03Multi-jurisdictional Asset Structuring
- 04Panama Relocation
Rothbard Group S.A.
A boutique cross-border tax and corporate advisory firm. Licensed U.S. Enrolled Agent authorized to practice before the Internal Revenue Service.