Areas of Expertise
U.S. and International Tax and Business Transactions
Individuals or companies with international assets and/or business interests must consider not only the applicable laws of each Country, but also the tax implications of both the U.S. and relevant foreign jurisdictions. Mr. Malley assists non-U.S. clients in planning for U.S. legal, regulatory, and tax issues, and U.S. clients in their business transactions and arrangements overseas.
Transnational Estate and Tax Planning
Estate planning involves consideration of estate, gift and income taxes. U.S. persons with overseas assets, and foreigners with U.S. assets, require specialized professional advice to avoid negative tax and probate issues.
U.S. taxpayers with foreign spouses are particularly vulnerable to negative tax consequences absent appropriate planning.
Foreign persons with U.S. assets can be subject to U.S. gift tax, and, on death, to U.S. estate tax.
Pre-Immigration Tax Planning
Persons immigrating to the U.S., either permanently or for temporary employment, will be subject to tax on worldwide income. Depending on circumstances, planning before arriving in the U.S. may minimize exposure to U.S. income and estate tax.
Asset Preservation Planning
Mr. Malley provides tax and asset protection planning for United States citizens and for foreign nationals. Asset preservation should be considered in any estate plan.
There are many planning opportunities to achieve this protection, depending on factors such as the extent and location of assets, and the individual's family arrangements, beneficiaries, and other planning goals, which may include privacy and anonymity.
Captive Insurance Arrangements
Captive insurance structures offer opportunities for tax advantaged company funded insurance when coverage might not otherwise be available or to minimize the cost of insurance. Captives must meet financial and regulatory guidelines.
Transnational Licensing, for manufacturing or for intellectual property, requires analysis of purpose, tax issues and opportunities in relevant countries, and carefully prepared documents.