Hutchinson and Bloodgood LLP offers a “Pre-Immigration Educational Package” to assist inbound and outbound executives with the complex international tax issues that they may face with a global employment assignment. This educational package provides pre-immigration tax planning for inbound and outbound executives.
Our “Pre-Immigration Educational Package” consists of a partner level meeting or phone conference with the executive and the executive’s employer. Once the issues are identified, they are summarized in a memo to the executive, and included in the fee are brief follow up questions. In the memo we identify practical and tactical issues and opportunities for further follow up at our hourly rates and in coordination with the employer and the foreign country tax advisor.
The conversation with the executive begins with of an introduction to the US tax system as it relates to their circumstances. For the inbound executive, we cover the unique aspects of the transition year from non-resident alien to resident alien. We analyze the potential start date of US tax residency, looking for treaty relief when necessary. We identify potential opportunities to accelerate income to shield it from US and state taxation. We look at ownership of foreign entities (holding companies are quite common with these executives) and discuss the US compliance impact. For the outbound executive we explain the foreign earned income exclusion, foreign tax credits, tax equalization; state residency and practical considerations related to the overseas assignment. For both inbound and outbound executives we have a checklist of common areas of concern and opportunity and identify which are relevant to the executive. Through these conversations with the executives and their employers we are able to proactively identify areas which merit more analysis. This is a very personalized package much appreciated by both the executives who have participated in the process, and by their employers who have invested so much in the global assignment.