International Tax Structuring & Legal Advisory
Strategic Legal Counsel for Global Investors, Entrepreneurs, and International Families
In today’s global economy, taxation does not stop at borders. Individuals and businesses operating across jurisdictions face complex exposure to U.S. federal tax laws, international reporting obligations, treaty implications, and cross-border structuring risks.
Natale Law provides sophisticated international tax strategy and legal advisory services for foreign investors entering the United States, U.S. citizens investing abroad, multinational entrepreneurs, and international families with global assets.
We focus on legal structuring, risk mitigation, and long-term strategic tax positioning, working in coordination with certified tax professionals when compliance or reporting is required.
Cross-Border Tax Structuring
Proper entity selection and structural planning are critical before entering the U.S. market or expanding internationally.
We advise on:
• U.S. inbound investment structuring
• Tax-efficient holding company formations
• LLC vs. Corporation vs. Partnership analysis
• Foreign ownership of U.S. entities
• Multi-jurisdiction business structuring
• Pre-investment tax impact analysis
Our approach is proactive. We structure transactions correctly from the beginning to avoid costly restructuring later.
Foreign Investment in U.S. Real Estate
International investors acquiring U.S. real estate are often exposed to complex rules, including FIRPTA withholding, capital gains taxation, and estate tax exposure.
We provide:
• FIRPTA legal guidance
• Structuring for foreign buyers
• Pre-construction contract tax analysis
• Estate tax mitigation strategies
• Exit strategy planning
Strategic planning before acquisition can significantly reduce the long-term tax burden.
U.S. Tax Exposure for Non-Residents
Foreign nationals frequently underestimate their exposure to U.S. tax laws.
We advise on:
• U.S. source income determination
• Permanent establishment analysis
• Effectively Connected Income (ECI) considerations
• Withholding obligations
• Double taxation risks
Understanding residency classification and income sourcing rules is essential to avoid unexpected liability.
International Estate & Wealth Planning
Cross-border families face unique estate and gift tax challenges.
Our services include:
• U.S. estate tax exposure for non-resident aliens
• Cross-border inheritance planning
• Trust structuring strategies
• Gift tax planning
• Asset protection coordination
We design structures that preserve wealth across generations while minimizing cross-jurisdiction risk.
Tax Treaty & Double Taxation Advisory
The United States maintains tax treaties with numerous countries. Proper interpretation of treaty provisions can dramatically impact liability.
We provide:
• Treaty application analysis
• Residency tie-breaker evaluation
• Withholding rate reduction strategies
• Cross-border income allocation planning
Treaty misinterpretation can be costly. Strategic analysis is critical.
IRS International Matters
When issues arise, experienced legal guidance is essential.
We assist with:
• IRS international inquiries
• Voluntary disclosure strategy
• Offshore reporting risk mitigation
• Penalty exposure analysis
Our objective is to resolve matters efficiently while protecting your legal and financial position.
A Strategic, Not Reactive, Approach
International taxation is not merely about compliance — it is about long-term planning.
Natale Law provides strategic legal analysis and structuring in coordination with certified tax professionals when tax return preparation, accounting, or reporting services are required. This integrated approach ensures clients receive both legal protection and technical compliance support.
Who We Represent
• Foreign investors entering the U.S. market
• International real estate buyers
• U.S. citizens investing abroad
• Cross-border entrepreneurs
• Multinational families
• Private investors and closely held businesses
Why Strategic Planning Matters
Cross-border taxation mistakes are rarely small. Improper structuring can lead to:
• Double taxation
• Withholding penalties
• Estate tax exposure
• IRS enforcement actions
• Expensive restructuring
Proactive legal planning protects capital, preserves wealth, and provides clarity before transactions occur.
Schedule a Confidential Consultation
If you operate across borders, your tax strategy should as well.
Contact Natale Law to discuss your international tax structure and cross-border exposure.
English