Every situation is different. A consultation with a senior advisor provides the Day 1 certainty you need to arrive protected, turning technical complexity into a clear, stress-free path to US residency.
Pre-immigration tax planning for green cards: Structure your assets before the US tax system takes hold
The moment you enter the US with a Green Card, the IRS claims your worldwide income, foreign business interests, and every asset you've built. What you do before that date determines how much of it you keep.
- 50+ US immigrant countries
- 180+ client countries worldwide
- 15+ years specialized experience
Who we help: Foreign founders & high-net-worth individuals on the path to US residency
We work with foreign nationals who have built meaningful wealth outside the US and are now pursuing permanent residency. If you have foreign business interests, appreciated assets, or complex holdings, the window to act is now, before you first set foot in the US with your new Green Card.
What goes wrong without pre-immigration planning
These are the mistakes we see most often, and the ones that prove most expensive once you're already inside the US tax net.
No cost basis step-up
Without a step-up before you immigrate, the IRS taxes your entire gain from the original purchase price, not from the date you arrived. Foreign real estate, equity, and business interests are all exposed.
PFIC-exposed investments
Foreign mutual funds and non-US insurance are often classified as PFICs, carrying punitive tax rates. Most immigrants only discover this exposure once they've already filed their first US tax return.
Unplanned CFC exposure
Once you hold a Green Card, your foreign company may become a Controlled Foreign Corporation subject to NCTI (formerly GILTI) tax. You could be taxed in the US on profits your foreign company hasn't even distributed to you yet.
Our expertise: Deep technical knowledge of the tax exposure immigrants face & how to address it
Whether you're holding a foreign operating business or a real estate portfolio, our goal is the same: to turn your global assets into a compliant, optimized US footprint that works for you from the moment you arrive.
Areas we typically address:
- Cost basis step-up strategies
- Check-the-box elections
- PFIC identification & divestiture
- CFC & NCTI (formerly GILTI) exposure mitigation
- Pre-immigration trust structuring
- Foreign tax credit optimization
Our approach: Plan now. Arrive protected.
Pre-immigration tax planning is time-sensitive by definition. We move methodically to convert a high-stakes transition into a seamless arrival, giving you the peace of mind to focus on your next chapter in the US.
Comprehensive discovery
We map your foreign holdings and assess the US tax exposure each carries from day one.
Integrated strategy design
We identify which assets to sell, restructure, or elect, and where a trust is warranted.
Structured implementation
We coordinate all filings, elections, and entity formations within your immigration timeline.
Post-arrival partnership
We manage your annual US tax filings, ensuring long-term protection and total compliance.
Not sure what to do before you arrive in the US?
If you are unsure which of your assets will be exposed once you enter the US with your new green card, a free 30-minute discovery call is the right first step. We will review your foreign holdings and immigration timeline, and explain what a formal written analysis would cover.
For many clients, that analysis is a pre-immigration memo listing what to sell, rebase or restructure before stepping foot into the US: PFIC funds, basis step-up opportunities, foreign companies that would become CFCs, trust structuring and check-the-box elections.
Because these steps only work before you become a US tax resident, most clients start here.
FAQ: What clients ask us
Collapsed content for Do I need to complete planning before I physically move to the US?
Yes. Most pre-immigration strategies must be implemented before you become a US tax resident. Once you enter the US as a Green Card holder or otherwise trigger US tax residency, many planning opportunities either disappear or become significantly more limited.Collapsed content for What is a PFIC, and why is it a problem for new US residents?
PFIC stands for Passive Foreign Investment Company. Many non-US mutual funds, ETFs, investment wrappers, and certain insurance products can fall into this category. Once you become a US tax resident, PFICs may be subject to punitive taxation, complex annual reporting, and interest charges. Identifying these investments before immigration is one of the most important parts of the planning process.Collapsed content for Will my foreign company become taxable in the US after I immigrate?
Potentially, yes. Once you become a US tax resident, ownership in certain foreign corporations can trigger Controlled Foreign Corporation (CFC) reporting and NCTI (formerly GILTI) tax exposure, even if profits are not distributed to you personally. Proper restructuring before immigration can often significantly reduce future complexity and tax exposure.Collapsed content for Can I reset the tax basis of my assets before becoming a US resident?
In many cases, yes. Pre-immigration planning may allow certain assets to be sold, rebased, transferred, or restructured before US residency begins, potentially reducing future US capital gains tax exposure. The appropriate strategy depends heavily on your country of residence, asset types, and immigration timeline.Work with us: The planning only works before you arrive. Start now.
Your residency date is a hard deadline. Once you enter the US as a permanent resident, the IRS treats every asset you own as subject to US tax. Speak with a senior advisor before the window closes.
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