By the time these issues surface, the cost to restructure is almost always higher than the cost of getting the structure right initially.
Offshore business structuring: Build it right before growth makes it expensive
The wrong structure costs more to unwind than it ever saved. We design offshore structures from first principles, built around your business, your jurisdictions, and your growth trajectory.
- 1,000+ offshore structures designed
- $1bn+ in tax liability reduced
- 15+ years specialized experience
Who we help: Global founders with US & international operations
We work with US citizens and green card holders running businesses across multiple jurisdictions. If your structure hasn't kept pace with your business, we'll get it right before it becomes expensive to fix.
What goes wrong without the right structure
These are the three issues we encounter most often and that prove most costly when left unaddressed.
IP in the wrong entity
Intellectual property held domestically that should have been transferred offshore before it appreciated, making the move prohibitively expensive.
Transaction tax exposure
A structure that functions during operations but triggers an avoidable tax event at the point of sale, acquisition, or liquidity, because the exit was never planned for.
Transfer pricing gaps
Related entities transacting without documented arm's-length pricing, creating audit exposure across multiple jurisdictions.
Our expertise: Experience across every major jurisdiction.
Hong Kong, the Cayman Islands, the UAE, Delaware, Singapore — we know where the trade-offs are, where the audit exposure hides, and which structures best support specific objectives. Every engagement draws on that experience.
Areas we address:
- Entity structuring & selection by jurisdiction
- CFC analysis & planning
- IP holding & royalty structure planning
- Treaty-based ownership layering
- Transfer pricing between related entities
- Cross-border trust strategy
What this is not
We don't sell structures: we design them, and we only recommend an offshore approach where it's genuinely warranted by your business model, residency, and risk profile. If your current structure is sound, we'll tell you. If it isn't, we'll show you exactly why and what it would take to restructure effectively.
Our approach: Strategy first. Compliance follows.
We don't just set up entities. We design a structure built around your business, then ensure it stays optimized and fully compliant as your operations grow.
Comprehensive discovery
We map your business model, ownership structure, and cross-border exposure across jurisdictions.
Integrated strategy design
Entity type, jurisdiction, IP holding, and transfer pricing: every layer considered together.
Structured implementation
We work with our legal team and local partners to establish entities and meet requirements.
Ongoing compliance
As your business scales, we adapt your structure accordingly and keep it tax-compliant.
Not sure where to start?
If you are unsure whether you need an offshore company at all, a free 30-minute discovery call is the right first step. We will review your business model, ownership and locations, identify the key structuring questions, and explain what a formal written analysis would cover.
For many founders, that analysis is a structuring memo comparing your options side by side: a US LLC or C Corp versus a foreign company, a jurisdiction shortlist, CFC and NCTI (formerly GILTI) exposure, Subpart F, IP ownership, and the US reporting for each option. It gives you a documented position to share with your lawyer, bank or investors before any entity is formed.
Most of our larger structuring engagements begin here.
FAQ: What founders ask us
Collapsed content for Do I really need an offshore company or foreign structure, or would a US LLC or corporation work better?
Whether an offshore or foreign company is better than just a US business setup depends on various factors, including residency, operations, IP ownership, banking, future exit plans, and US anti-deferral rules like NCTI and Subpart F. We compare different options to give you a full picture.Collapsed content for Will setting up an offshore structure trigger any US reporting requirements or penalties?
Yes, offshore structures typically come with US reporting obligations, including forms like FBAR, Form 5471, Form 8938, and potentially Form 8865 or Form 926, depending on the entity type and your ownership percentage. Missing these filings can result in substantial penalties, so we map out all reporting requirements as part of the structuring process.Collapsed content for I already have an existing US LLC or corporation. Can I still set up an offshore structure, and how would the two entities interact?
Yes, having an existing US entity does not preclude adding a foreign structure, but the relationship between the two needs to be carefully designed. Depending on your goals, the offshore entity might sit above, below, or parallel to your US entity, and each configuration carries different tax, liability, and operational implications. We review your current setup and model out how a foreign structure would interact with it before recommending anything.Collapsed content for Can I use an offshore company to hold intellectual property and reduce my overall tax burden?
IP holding structures can be effective, but they require careful planning to withstand IRS scrutiny, particularly around transfer pricing, substance requirements, and anti-deferral rules. The right approach depends on where the IP was developed, how it is licensed, and whether the structure has genuine economic substance beyond tax minimization.Work with us: Discover what a better structure is worth to you.
Speak with a tax & structuring expert. We'll review your situation and identify exactly where you're exposed, and what the right structure would look like.
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