For Global Citizens & Cross-Border Families
Dual citizenship, foreign domicile, non-U.S. beneficiaries, and offshore IDFs turn a complex transaction into a multi-jurisdiction one — where a single misstep on treaty positions or reporting can void the structure. Integrity coordinates international tax counsel and offshore specialists so the pieces fit under U.S. and foreign law alike.
The cross-border problem
For globally mobile families, the failure points multiply. The offshore entity's classification under U.S. tax law, the treaty position, PFIC and CFC exposure, and the family's FATCA and CRS obligations all have to be resolved together — by counsel who practices across the relevant jurisdictions.
Misstructure any one of these — even subtly — and the consequences range from retroactive loss of tax treatment to inadvertent disclosure and penalty exposure. Coordination is not a convenience here; it is the safeguard.
What international tax counsel resolves
Treaty & entity classification
Advises on treaty positions and how the offshore entity is classified under U.S. tax law before the structure is set.
PFIC & CFC analysis
Evaluates passive foreign investment company and controlled foreign corporation exposure across the IDF sleeve.
FATCA & CRS compliance
Ensures reporting obligations are met to prevent inadvertent disclosure or penalty exposure for the family and its entities.
Jurisdictional situs
Offshore domicile in Liechtenstein, Cayman, or Bermuda — or favorable U.S. trust states — anchored by specialized counsel.
One coordinator across borders
The PPLI Coordinator keeps domestic and international counsel, the offshore IDF manager, and the trust company aligned to a single sequenced timeline — so the structure that works in one jurisdiction doesn't break in another.
Bring us a cross-border family whose structure has to satisfy U.S. and foreign law at the same time. We'll assemble the international team and own the sequence so nothing falls between jurisdictions.
Other advisor streams