CRISTIANA CONCEPCIÓN
Experiencia
The following are representative matters that
Christine has handled:
Pre-Immigration Tax and Estate Planning
- Counsel to a high-net-worth individual relocating to the United States in pre-immigration tax planning, including the restructuring of foreign business interests, PFIC holdings, and foreign trust arrangements before the residency starting date.
- Counsel to a high-net-worth European individual in pre-immigration tax planning ahead of relocating to the United States on an investor visa. The work included settling a foreign grantor trust before the residency starting date, restructuring wholly owned foreign companies through entity classification elections so the entities are disregarded and the trust is treated as a grantor trust for U.S. tax purposes, and structuring the acquisition of U.S. real estate to be held outside the client’s U.S. taxable estate.
- Counsel to an ultra-high-net-worth green card holder with significant U.S. assets, married to a non-citizen spouse, in estate planning designed to bridge the period until both spouses became naturalized U.S. citizens. The planning used qualified domestic trusts (QDOTs), intentionally defective grantor trusts (IDGTs), and irrevocable life insurance trusts (ILITs) to reduce exposure caused by the unavailability of the unlimited marital deduction and the limits on portability for non-citizen spouses.
Outbound Tax Planning
- Counsel to a U.S. citizen relocating abroad while owning multiple U.S. businesses regarding permanent establishment risk, entity restructuring, potential dual-filing obligations, compensation planning, and social security totalization.
- Counsel to a U.S. citizen living abroad in restructuring an investment portfolio to eliminate PFIC exposure and meet ongoing U.S. tax reporting obligations.
- Counsel to a U.S. citizen resident in living abroad in correcting prior-year U.S. returns that failed to account for her foreign assets, including interest in foreign entities, pension plans and bank accounts.
Expatriation Tax Planning
- Counsel to a long-term U.S. resident through the expatriation process under IRC Section 877A, including covered expatriate determination, exit tax modeling, pre-expatriation restructuring, and final-year compliance including Form 8854.
International Tax Compliance and Offshore Disclosure
- Counsel to an ultra-high-net-worth non-resident individual in the U.S. tax analysis, compliance remediation, and restructuring of a multi-tiered holding structure with entities in the United States, Panama, Singapore, the British Virgin Islands, and the Cayman Islands, including entity classification elections, FBAR and information return obligations, and coordination with foreign counsel.
- Counsel to non-willful taxpayers in the IRS Streamlined Filing Compliance Procedures regarding unreported foreign bank accounts and unfiled international information returns across multiple tax years.
U.S. Real Estate Tax Planning for Foreign Investors
- Counsel to a foreign corporation owning a U.S. real property holding corporation with high-value residential and commercial real estate regarding restructuring alternatives, FIRPTA withholding, the application of nonrecognition exceptions, and estate tax exposure.
- Counsel to a foreign investor acquiring multiple Miami residential properties through a tiered holding structure regarding FIRPTA exposure, U.S. estate tax on U.S.-situs assets, entity formation, and ongoing income tax and reporting obligations.
- Counsel to a client in evaluating trust and LLC structures to hold high-value real estate where privacy of ownership and retained operational control were the primary objectives.
Cross-Border Inheritance Matters
- Counsel to the heirs of a Latin American decedent in a Florida summary administration involving U.S.-situs real estate, multiple non-U.S. beneficiaries, and a parallel foreign estate proceeding, including international service of process, the U.S. estate tax return, and the income tax consequences of post-death transfers among non-resident alien heirs.
- Counsel to the estate of a European decedent holding U.S.-situs assets in the preparation and filing of Form 706-NA, including certified translations of foreign notarial documents and ITIN procurement.
International Trust and Estate Planning
- Counsel to internationally mobile families in the structuring of foreign grantor and non-grantor trusts, usufruct arrangements under French and Spanish civil law, and cross-border life insurance, coordinating U.S. tax analysis with foreign counsel.
Cross-Border Business Structuring
- Counsel to the sponsors of a U.S. investment fund in structuring an investment in real estate in a Latin American country, including a U.S. partnership fund with a general partner and limited partner profit split, separate local country property-holding and operating companies, local country withholding tax on interest and dividend repatriation, and the U.S. income and self-employment tax treatment of the sponsors’ management compensation.
- Counsel to a U.S. construction engineering services company and its non-U.S. co-owner in cross-border structuring, including use of a foreign blocker entity to protect the non-resident owner from U.S. estate tax, entity classification elections and late-election relief for the U.S. and local country entities, and a proposed restructuring to acquire a local country service affiliate in connection with a third-party investment.
- Counsel to a foreign business and its foreign-owned U.S. services company serving global clients and suppliers regarding remediation of prior-year federal corporate filings, avoidance of permanent establishment exposure, and the ownership structure of a new U.S. venture with partners resident in multiple countries.
International Tax Due Diligence in M&A Transactions
- Counsel to a European institutional investor conducting U.S. tax due diligence of a U.S. target, including the validity of the entity classification election, multistate nexus and filing gaps, intercompany loan, licensing, and services arrangements, downward attribution rules, net operating loss carryforwards and Section 382 limitations, and the U.S. tax treatment of equity incentives held by U.S. employees.
Contacta con Christine
Teléfono: +1.305.444.6669 | Correo electrónico: caconcepcion@concepcionlaw.com