Cross-border tax planning
Operating across the US and Europe creates complex tax obligations. We help you navigate tax treaties, entity structure decisions, FBAR and FATCA reporting, transfer pricing, and exit tax — all coordinated with your immigration timeline.
What we handle
Cross-border tax is where immigration, corporate structure, and personal finances intersect. Your visa status affects your tax residency. Your entity structure determines how profits are taxed. And treaties between the US and your home country may reduce or eliminate double taxation — but only if you claim them correctly.
Tax treaty benefits
The US has tax treaties with Germany, France, Sweden, Norway, and most other European countries. These treaties can reduce withholding taxes on dividends, interest, and royalties, prevent double taxation of business profits, and determine which country has taxing rights over your income. We help you identify and claim applicable treaty benefits.
Entity tax structure
How your US entity is taxed depends on its structure. A single-member LLC owned by a foreign person is typically a disregarded entity for US tax purposes but may still have filing obligations. A multi-member LLC can elect partnership or corporate taxation. A C-corporation faces double taxation but offers other advantages. We advise on the structure that minimizes overall tax burden while supporting your visa case.
FBAR and FATCA
US persons (citizens, green card holders, and tax residents) with foreign financial accounts exceeding $10,000 at any point during the year must file an FBAR. FATCA imposes additional reporting requirements and causes European banks to request documentation from account holders with US ties. Non-compliance penalties are severe. We ensure you meet all reporting obligations.
Transfer pricing
If your US entity transacts with a related foreign entity — intercompany services, licensing, cost-sharing — transfer pricing rules require that these transactions be priced at arm’s length. Failure to document and justify transfer pricing can result in significant tax adjustments and penalties.
Exit tax
Renouncing US citizenship or abandoning a long-term green card triggers exit tax provisions. The US treats this as a deemed sale of all worldwide assets at fair market value. Understanding the implications before making this decision is critical — and timing it with your immigration status changes can significantly affect the outcome.
Further reading
- Tax Implications of Owning a US LLC as a European Resident
- The US-Germany Tax Treaty: Key Provisions for Expats and Investors
- The Full Legal Checklist for Moving Your Business to the US
- Opening a US Business Bank Account From Europe: A Step-by-Step Guide
- Five Easy Steps to Renounce Your US Citizenship
- FBAR Reporting: A Guide for US Citizens Living in Europe
- FATCA Explained: What European Banks Need From You
- Exit Tax: What to Know Before Giving Up Your Green Card or US Citizenship
- E-2 Visa and Your US LLC: How Entity Structure Affects Your Case
- Choosing the Right US State for Your LLC: Delaware, Wyoming, or Where You Operate