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International Practice

Cross-Border
Legal Planning for
the Globally Connected.

When your life, your business, or your family spans multiple countries, your legal and tax planning must keep pace. Calvary International Law provides sophisticated cross-border counsel for families, founders, and institutions operating across jurisdictions worldwide.

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12+
International Jurisdictions Served
50
US States — Of-Counsel Coverage
100%
FBAR & FATCA Compliant Structures
1
Unified Strategy Across Every Jurisdiction
Who We Serve

Built for Clients
Who Live Without Borders

Cross-border planning is not a niche specialty — it is a necessity for any globally mobile person or family with meaningful assets, business interests, or life circumstances that span two or more countries.

◈
US Citizens Living Abroad
Americans residing in Canada, Europe, the Middle East, or elsewhere face unique US tax obligations regardless of where they live. We coordinate foreign tax credits, treaty elections, FEIE planning, and estate structures that work across both countries.
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Foreign Nationals with US Assets
Non-resident aliens investing in US real estate, securities, or businesses face US estate tax exposure on those assets. We structure holdings to minimize US estate and gift tax while maintaining investment flexibility and avoiding withholding inefficiencies.
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Dual Citizens & Green Card Holders
Dual citizens and US permanent residents are subject to worldwide US taxation. We help clients understand their obligations, optimize their position across both jurisdictions, and — when appropriate — plan for expatriation or covered expatriate status.
◈
Cross-Border Business Owners
Operating a business that spans the US and one or more foreign jurisdictions creates transfer pricing, Subpart F, GILTI, and treaty compliance issues. We work with your accounting team to create entity structures that minimize global tax drag.
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Families Relocating Internationally
Whether moving to Switzerland, the UAE, or Canada, pre-immigration and pre-departure planning is essential. We help clients restructure their wealth, trusts, and business interests before changing tax residency to avoid costly and often irreversible tax consequences.
◈
Multi-Generational International Families
Families with members across multiple countries require estate plans that navigate conflicting inheritance laws, forced heirship rules, and multi-jurisdictional estate administration. We design structures that provide clarity, flexibility, and continuity across generations.
The Complexity We Navigate

Why Cross-Border
Planning Demands
Specialized Counsel

Most domestic estate planning attorneys are not equipped to handle the layered compliance obligations, treaty interactions, and jurisdictional conflicts that arise in international situations. We are built precisely for this complexity.

01
Dual Taxation & Treaty Navigation
Many countries tax the same income or estate from different angles. Tax treaties reduce — but do not eliminate — double taxation, and treaty elections are highly technical. We identify the optimal treaty position for each client's fact pattern and structure accordingly.
02
FBAR, FATCA & Foreign Account Compliance
US persons with foreign financial accounts or assets are subject to extensive reporting requirements — FinCEN 114, Form 8938, Form 3520, Form 5471, and others. Failure to comply can trigger penalties far exceeding the account value. We ensure structures are reporting-ready from inception.
03
Conflicting Inheritance & Forced Heirship Laws
Many civil law jurisdictions — including France, Germany, Switzerland, the UAE, and others — impose mandatory inheritance shares that override private trust or estate planning instruments. We design structures that achieve client objectives within or around these constraints.
04
Trust Recognition Across Jurisdictions
Not every country recognizes the common law trust as a legal entity. Foreign jurisdictions may recharacterize a trust as a taxable gift, a transparent entity, or ignore it entirely. We structure international trusts to function effectively whether recognized or not.
05
Pre-Immigration & Pre-Departure Planning
Once a client becomes a US tax resident or departs the US, many planning options close permanently. Pre-immigration planning — including trust contributions, business restructuring, and basis step-up strategies — must be executed before residency begins or ends.
06
PFIC, CFC & Passive Foreign Investment Traps
US shareholders in foreign corporations or foreign mutual funds face some of the most punitive provisions in the tax code — PFIC excess distribution regimes and Subpart F / GILTI inclusion rules. We identify these issues in advance and restructure to minimize their impact.
Jurisdiction Profiles

Our International
Jurisdiction Expertise

Each jurisdiction below offers distinct legal, regulatory, and tax characteristics. We select and structure across these jurisdictions based on each client's unique circumstances — not on popularity or convenience.

Trust & Privacy Havens
Tax-Favorable
Business & Commerce
All Jurisdictions
Cook Islands
South Pacific · Trust & Asset Protection
  • Self-settled spendthrift trusts with strong creditor protection
  • Among the most robust trust laws in the world
  • Foreign judgments not automatically enforceable
  • Ideal as foundation of international asset protection plans
Cook Islands trusts are frequently used in combination with Nevis LLCs to create layered, court-tested protection structures.
Nevis
Caribbean · LLC & Trust Formation
  • Nevis LLC provides charging order protection only
  • No US-style piercing of corporate veil doctrine
  • Combined with Cook Islands trust for maximum protection
  • Low-cost formation and maintenance
The Nevis LLC is the workhorse of many international protection plans — flexible, inexpensive, and highly resistant to US creditor collection.
Liechtenstein
Western Europe · Foundation & Trust Law
  • Unique Anstalt and Foundation structures unavailable elsewhere
  • Strong banking secrecy and regulatory environment
  • Recognized civil law jurisdiction — suitable for European clients
  • Ideal for EU-based families seeking non-EU trust structures
Liechtenstein's legal framework bridges civil law and common law traditions, making its structures particularly useful for mixed-jurisdiction families.
Isle of Man
British Isles · Trust & Estate Planning
  • Common law trust framework with strong statutory protections
  • Purpose trusts available for non-charitable purposes
  • Robust private trust company legislation
  • Well-regarded by UK and European clients
The Isle of Man is a preferred jurisdiction for clients with UK connections seeking a stable, well-regulated trust framework outside of UK jurisdiction.
United Arab Emirates
Middle East · Tax Residency & Wealth Holding
  • Zero personal income tax and capital gains tax
  • DIFC and ADGM provide Common Law frameworks for trusts and foundations
  • Growing treaty network reducing withholding on foreign income
  • Popular destination for pre-departure planning before US departure
The UAE's zero-tax environment makes it highly attractive for clients relocating from high-tax jurisdictions, though US persons remain subject to worldwide US taxation regardless of residency.
Switzerland
Western Europe · Private Banking & Tax Planning
  • Lump-sum taxation (forfait fiscal) for qualifying foreign residents
  • Extensive double tax treaty network
  • Premier private banking and asset custody environment
  • Stable legal system with strong property rights protections
Switzerland's combination of legal stability, treaty access, and private banking infrastructure makes it a cornerstone of many international wealth plans for European-connected families.
The Bahamas
Caribbean · Trust & Tax Planning
  • No income, capital gains, or estate tax
  • Bahamas Executive Entity (BEE) for private trust company structures
  • SMART Fund legislation for tailored investment structures
  • Common law jurisdiction with modern financial services regulation
The Bahamas offers a combination of tax efficiency, legal sophistication, and proximity to the US that makes it well-suited for certain high-net-worth planning scenarios.
Costa Rica
Central America · Territorial Tax & Residency
  • Territorial tax system — foreign-sourced income generally not taxed
  • Pensionado and Rentista residency programs
  • Asset holding through Sociedad Anónima (SA) structures
  • Growing expat and digital nomad planning destination
Costa Rica's territorial tax system and accessible residency programs make it popular for US retirees and remote workers — though US citizens remain subject to US tax obligations worldwide.
Cayman Islands
Caribbean · Investment Funds & Corporate
  • Premier jurisdiction for hedge funds and private equity structures
  • Exempted companies and partnerships widely used for investment vehicles
  • No direct taxation on income, capital gains, or corporate profits
  • Recognized internationally by institutional investors
The Cayman Islands is the global standard for institutional investment fund formation and is increasingly used for family office and co-investment vehicle structures.
British Virgin Islands
Caribbean · Business Company Formation
  • BVI Business Company (BC) — flexible and widely recognized
  • No taxes on income, capital gains, or distributions
  • Common law framework with strong confidentiality protections
  • Used as intermediate holding companies in cross-border structures
BVI companies are among the most widely used holding vehicles in international structures, valued for their flexibility, low cost, and broad international recognition.
Canada
North America · Cross-Border US-Canada Planning
  • US-Canada Tax Treaty provides significant planning opportunities
  • Canadian trusts and holding companies for US-connected families
  • Pre-departure planning for Canadians relocating to the US
  • Principal residence exemption and RRSP/TFSA cross-border treatment
The US-Canada corridor is one of the most heavily traveled cross-border planning environments. We navigate RRSP elections, treaty tie-breaker rules, and departure tax implications for clients moving in both directions.
Belize
Central America · Trust & Corporate
  • Belize International Trust — flexible and cost-effective
  • No taxation on income, gains, or dividends from foreign sources
  • International Business Company (IBC) formation
  • Common law jurisdiction with strong confidentiality
Belize offers accessible, cost-efficient structures that complement more established jurisdictions — particularly as a holding layer in multi-tier international plans.
Cook Islands
South Pacific · Trust & Asset Protection
  • Self-settled spendthrift trusts with strong creditor protection
  • Foreign judgments not automatically enforceable
  • Ideal as foundation of international protection plans
Nevis
Caribbean · LLC & Trust
  • Charging order protection only — no veil piercing
  • Combined with Cook Islands trust for maximum protection
  • Low-cost, flexible formation
Liechtenstein
Western Europe · Foundation & Trust
  • Unique Anstalt and Foundation structures
  • Bridges civil and common law traditions
  • Preferred for EU-connected clients
United Arab Emirates
Middle East · Tax Residency
  • Zero personal income and capital gains tax
  • DIFC/ADGM Common Law frameworks
  • Popular pre-departure destination
Switzerland
Western Europe · Private Banking
  • Lump-sum taxation for qualifying residents
  • Extensive double tax treaty network
  • Premier private banking environment
The Bahamas
Caribbean · Tax & Trust
  • No income, capital gains, or estate tax
  • Bahamas Executive Entity for private trust companies
  • Modern financial services regulation
Costa Rica
Central America · Territorial Tax
  • Territorial tax system — foreign income generally exempt
  • Accessible residency programs
  • SA corporate structures for holding
Cayman Islands
Caribbean · Investment Funds
  • Premier fund formation jurisdiction globally
  • No direct taxation on income or gains
  • Recognized by institutional investors worldwide
British Virgin Islands
Caribbean · Holding Companies
  • BVI BC — flexible, widely recognized
  • No taxes on income or capital gains
  • Used as intermediate holding layers
Canada
North America · US-Canada Planning
  • US-Canada Tax Treaty planning
  • Pre-departure and pre-immigration planning
  • RRSP/TFSA cross-border treatment
Belize
Central America · Trust & Corporate
  • Belize International Trust — flexible and cost-effective
  • No taxation on foreign-sourced income
  • IBC formation
Isle of Man
British Isles · Trust Planning
  • Common law trust with purpose trust capability
  • Private trust company legislation
  • Preferred by UK-connected clients
Compliance Architecture

Structures Designed to
Comply — Not Just to Plan

International structures that generate compliance exposure are liabilities, not assets. Every structure we design is built with the reporting architecture in place from day one.

IRS / FinCEN
FBAR & FATCA Reporting
FinCEN 114 (FBAR) and Form 8938 (FATCA) reporting for foreign accounts and specified foreign financial assets. We design structures with built-in reporting clarity and coordinate with your CPA on annual filings.
IRS Forms
Foreign Trust Reporting (3520 / 3520-A)
US persons with foreign trusts face annual reporting obligations. We coordinate proper reporting of trust distributions, contributions, and ownership interests to ensure full compliance and avoid substantial penalties.
Subpart F / GILTI
Controlled Foreign Corporation Rules
US shareholders of foreign corporations may be required to include Subpart F income or GILTI in gross income currently. We structure CFC ownership and earnings to minimize these inclusions where legally permissible.
IRC § 1291
PFIC Compliance & Elections
Passive foreign investment companies are subject to one of the harshest tax regimes in the US code. We identify PFIC exposure and make appropriate QEF or mark-to-market elections to avoid the punitive default regime.
Form 5471
Foreign Corporation Reporting
US shareholders, officers, and directors of foreign corporations may have Form 5471 filing obligations. We ensure timely and complete filing while using the reporting as a planning tool to monitor income categories.
IRC § 877A
Expatriation & Covered Expatriates
Clients considering renouncing US citizenship or abandoning a Green Card must understand the Section 877A exit tax regime and covered expatriate rules. We provide pre-expatriation planning to minimize the exit tax where possible.
How We Work

Our Cross-Border Planning
Engagement Framework

International planning is not a product — it is a process. Our engagement framework ensures that every dimension of your cross-border situation is assessed, addressed, and maintained over time.

01
Cross-Border Situation Analysis
We begin with a comprehensive review of your tax residency, citizenship, domicile, asset locations, entity holdings, and family structure across every relevant jurisdiction. This mapping exercise is the foundation of every international engagement.
Residency Analysis Asset Mapping Treaty Review Compliance Audit
02
Jurisdiction Selection & Structure Design
Based on your objectives, we select the optimal jurisdictions and entity types — trusts, foundations, LLCs, corporations, or combinations thereof — and design the layered structure with tax efficiency, legal protection, and compliance architecture as co-equal priorities.
Trust Design Entity Selection Tax Modeling Treaty Optimization
03
Coordinated Professional Team Assembly
International plans require specialists in each relevant jurisdiction. We assemble and coordinate the team — foreign counsel, international CPAs, private bankers, compliance specialists, and trust companies — ensuring each professional works from the same strategic blueprint.
Foreign Counsel International CPA Private Banking Trust Administration
04
Implementation & Documentation
We draft or coordinate all governing documents — trust deeds, operating agreements, shareholder agreements, and protectorate arrangements — and oversee the sequential implementation that ensures legal effectiveness in each jurisdiction.
Trust Deeds Operating Agreements Asset Transfers Bank Account Setup
05
Ongoing Reporting & Annual Maintenance
Cross-border structures require annual attention — FBAR filings, Form 3520 reporting, trust accounts, and periodic review as laws change. We provide ongoing counsel and coordinate with your accounting team to ensure your structure remains compliant and optimized year after year.
FBAR / FATCA Form 3520 Annual Reviews Law Change Monitoring
Illustrative Scenarios

How We've Approached
Complex Cross-Border Situations

The following scenarios are illustrative examples of the types of planning we undertake. They do not represent any specific client matter and should not be construed as legal advice.

Scenario 01
US Entrepreneur Relocating to the UAE
A US citizen with a $12M business and investment portfolio intends to move to Dubai. He wants to minimize US tax going forward while maintaining flexible access to his investments.
Our Approach Pre-departure restructuring of business holdings, analysis of GILTI and Subpart F exposure on foreign entities, FBAR/FATCA compliance architecture, and coordination with UAE legal counsel on residency structure. Note: US citizenship means ongoing worldwide US tax obligations regardless of residency.
Scenario 02
Canadian Family with US Real Estate
A Canadian couple owns $4M in US vacation and investment properties. They are not US persons but are concerned about US estate tax exposure on their US assets at death.
Our Approach US estate tax analysis for non-resident aliens, use of Canadian holding entity or US blocker structure to remove properties from direct US estate tax exposure, treaty analysis, and coordination with Canadian tax counsel on cross-border ownership structure.
Scenario 03
Multi-Generational Family Across Three Countries
A family has members in the US, Switzerland, and the UK. The patriarch wants to create a unified legacy structure that works across all three jurisdictions and avoids forced heirship issues.
Our Approach Liechtenstein or Isle of Man trust as the apex structure, coordinated with US irrevocable trust for US assets, Swiss banking for custody, and UK-compliant sub-structures for UK beneficiaries. Annual reporting architecture across all three reporting regimes.
Scenario 04
Green Card Holder Considering Abandonment
A long-term US Green Card holder from Brazil has decided to return home permanently after 15 years in the US. She holds $8M in assets and wants to understand her departure tax obligations.
Our Approach Analysis of covered expatriate status under IRC §877A, exit tax calculation on deemed disposition of assets, pre-abandonment gifting and restructuring strategies, coordination with Brazilian counsel on receipt of assets, and I-407 filing guidance.
Scenario 05
Foreign National Immigrating to the US
A UK citizen with a Liechtenstein foundation and Swiss banking relationships is immigrating to the US on an EB-5 visa. She wants to preserve her existing structures while becoming US tax-compliant.
Our Approach Pre-immigration trust planning before US residency begins, analysis of Liechtenstein foundation treatment under US tax law, Section 679 and Section 684 exposure analysis, PFIC review of foreign investment holdings, and FBAR/FATCA compliance setup prior to residency commencement.
Scenario 06
Cross-Border Business Sale
A US citizen owns a business with operations in Costa Rica and the US. He is negotiating a sale to a European buyer and wants to optimize the transaction structure across both jurisdictions.
Our Approach Transaction structure analysis for US and Costa Rica tax treatment of sale proceeds, treaty analysis for European buyer's withholding obligations, installment sale and earnout structuring, and coordination with Costa Rican counsel and transaction tax accountants.

Your World Doesn't Fit
in One Jurisdiction.
Neither Should Your Plan.

Contact Calvary International Law to schedule a confidential consultation on your cross-border planning needs. Our engagements begin with a thorough analysis — not a template.

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