Jurisdiction · United States
United States: tax, residence, structures and accounts
The US taxes citizens and green-card holders on worldwide income (citizenship-based taxation) and polices foreign assets through FATCA and FBAR. For non-residents the key topics are estate tax with its US-situs trap, the US LLC (Wyoming/Delaware) and its reporting, and funds. This hub gathers everything we write on the US for private capital.
taxation
citizenship-based
asset reporting
FATCA · FBAR
estate tax · non-resident
40% · $60k exemption
structures
US LLC · WY / DE
library
banks & neobanks
Licensed banks and neobanks for corporate, personal and private banking accounts.
Airwallex: business neobank for multi-currency accountsAirwallex is a business neobank for multi-currency accounts, cards, payment acceptance, API payouts, safeguarding and sanctions-sensitive onboarding checks.read →Arca: AI Wealth Management PlatformArca exited stealth with $64M for AI wealth management: equity comp, tax and estate planning. Who can use it, regulation status and non-US access.read →BaaS: How a Banking Product Lives Without a LicenseA guide to BaaS: US sponsor banks, middleware (Unit, Treasury Prime, Synctera), the Synapse lesson, and the EMI model in Europe. How to launch a banking product without your own license.read →Banking for US Citizens Abroad: Who Still Opens Accounts and What FATCA DemandsWhich banks still open accounts for US citizens living abroad: FATCA friction, the willing-bank categories (US desks, Swiss/EU and HK/SG private banks), W-9 and self-certification, and the FBAR/8938 parallel track.read →BNY (Bank of New York Mellon): World's Largest Custodian, BNY Wealth and PershingBNY (Bank of New York Mellon) — oldest U.S. bank (1784) and world's largest custodian: ~$59.4 trillion in assets under custody/administration, BNY Investments, BNY Wealth and Pershing.read →Column N.A.: The Developer Bank for BaaS ProgramsColumn N.A. — a nationally chartered developer bank from Plaid's co-founder: direct APIs, no middleware, Brex, Plaid and Mercury programs, partner criteria.read →Cross River Bank: The Sponsor Bank Behind US FintechCross River Bank — the sponsor bank behind Affirm, Coinbase and Circle: how sponsorship works, the 2023 FDIC consent order, partner criteria and IPO plans.read →Equals Money: British account for Americans and companies with significant FX demandEquals Money is a UK fintech for companies and US-linked clients with significant FX needs: account features, currency operations, and suitability limits.read →Erebor Bank: Peter Thiel and Palmer Luckey's bank under the mountainErebor is the new U.S. national bank from Peter Thiel and Palmer Luckey: stablecoins on the balance sheet, ~$4B in deposits, $8B valuation talks, an OCC charter in 2026. Who's behind it and how to get exposure.read →Goldman Sachs Private Wealth Management UK: $10M+ Entry and Institutional UHNWGoldman Sachs Private Wealth Management UK: London UHNW service under FCA/PRA, $10M+ threshold and fit for private clients.read →Grasshopper Bank: The US Digital Bank for Startups and SMBsGrasshopper Bank — a US digital bank on its own national charter: startup and SMB banking, BaaS, SBA lending and the $369M Enova deal explained for clients.read →HEVN: Cross-Border Business Banking API Platform – Local EU/US/UAE Accounts, Stablecoins & PayrollHEVN is a Y Combinator fintech for cross-border business: named local accounts in EU, US, and UAE via partner banks, SEPA/ACH/SWIFT/UAEFTS and stablecoin payments, API and cards. Not a bank.read →J.P. Morgan Private Bank UK: US-origin UHNW in London — investment banking expertise and £10M+ entryJ.P. Morgan Private Bank UK: London UHNW hub with GBP10M+ threshold, investment-bank integration, UK regulation and client selection.read →J.P. Morgan: Corporate & Investment Bank and Private Bank of JPMorgan ChaseJ.P. Morgan is the corporate, investment, and private banking arm of JPMorgan Chase, the largest U.S. bank (G-SIB): private bank for UHNW from $10M, USD clearing network.read →Lead Bank: The Kansas City Sponsor Bank for Fintech ProgramsLead Bank — the Kansas City sponsor bank behind Affirm, Ramp and Bridge/Visa stablecoin cards: ex-Square team, Missouri charter and program criteria.read →MercuryMercury is a US fintech banking platform for startups and US companies. How it fits payment infrastructure for private capital and non-resident limits.read →PayoneerPayoneer is a public fintech for marketplace revenue collection and cross-border payouts. Account features, limits, and suitable company profiles.read →Rent-a-Bank and True Lender: Whose Rate Backs the LoanHow non-banks lend through partner banks to export interest rates, the true lender doctrine, and which states have opted out of DIDMCA—Colorado, Oregon (HB 4116, 2026).read →Wise BusinessWise Business is a multi-currency payment account for companies, with local account details, onboarding, FX, and limits for cross-border settlements.read →
library
tax & investments
Tax regimes, investment transactions, CFC, ESOPs, secondaries and private capital.
Anchorage Digital: Crypto Custody Under Federal Banking LicenseFirst crypto bank with federal OCC charter: asset segregation, staking from custody, governance tools for funds and family offices.read →AngelList: How a Family Office Runs "Club" DealsHow family offices use AngelList to run syndicates: deal-by-deal SPVs, fund administration, banking, and platform fees. Infrastructure for direct venture investing.read →Carried interest 2026: the jurisdiction map for fund principalsHow carried interest taxation changed in 2026: the UK moves it into trading profits (34.1%/47%) and reaches non-residents, Luxembourg offers 11.45% or exemption, Italy 26%, France the 31.4% PFU, and the US keeps § 1061 intact.read →Carta: Cap Table Management, Fund Administration, and a Data Privacy LessonHow Carta became the industry standard for cap table management and fund administration, and why it exited secondary trading after a 2024 data scandal.read →CFC and PFIC Rules Stacked: A US Person with EU Residence and an Offshore CompanyHow US CFC and PFIC rules stack with EU ATAD CFC rules on one offshore company: the CFC/PFIC overlap rule, the parallel EU layer, and the legitimate outs — active business, thresholds, elections.read →Coinbase Prime: Crypto Prime Brokerage of a Public CompanyCustody, execution, and financing within a public company framework: how Coinbase Prime works and who it suits for institutional digital asset management.read →FATCA, FBAR and Form 8938How FATCA, FBAR and Form 8938 work for U.S. persons abroad: foreign bank reporting, FinCEN Form 114, specified foreign financial assets and penalties.read →FEIE and foreign tax creditHow U.S. persons abroad choose between foreign earned income exclusion and foreign tax credit: Form 2555, Form 1116, housing exclusion and double-tax rules.read →Fireblocks: The Infrastructure Behind Everyone ElseMPC wallets, policy engine, and transfer network powering exchanges and banks; how family offices use Fireblocks indirectly through their custodians and managers.read →Foreign trusts and Form 3520How U.S. persons approach foreign trusts, gifts, inheritance, Form 3520, Form 3520-A, grantor trust status and estate planning controls.read →Forge Global: Full-Stack Secondary Market—Now Under SchwabFull-stack private equity secondary market—brokerage, custody, Forge Price data; the Charles Schwab acquisition and what it changes for accredited investors.read →Hiive: Order Book for Private Company SharesOrder book for pre-IPO: direct matching of buyers and sellers of private company shares, transparent quotes, and investor access.read →How National Security Review worksNational Security Review screens foreign investments for security threats. How the process works, which deals trigger it, and what it means for cross-border structuring.read →How to invest in unicorn shares on the secondary marketHow to buy pre-IPO unicorn shares on the secondary market: deals between existing shareholders. Access, structures and minimums for private-capital investors.read →iCapital: The Alternative Investment "Plumbing" You Don't SeeThe B2B platform through which banks and advisors distribute PE, private credit, and hedge funds: feeder funds, document flow, and technology stack.read →Kraken: Crypto Exchange for Institutional Clients and Private WealthThe oldest major crypto exchange: Wyoming SPDI charter, Kraken Prime, MiCA license in the EU, and Proof of Reserves. Institutional stack and banking custody.read →Lock-up Period: Why Shares Cannot Be Sold Immediately After IPOLock-up period after IPO: what it is, standard 90–180 day terms, underwriter's right to early release, and why the restriction is doubly critical for SPV and secondary market investors.read →Masterworks: How to Buy a Share in Banksy Without Buying the PaintingSecuritization of paintings through SEC-registered offerings: fees, secondary market, actual returns, and risks of fractional art investment.read →Nasdaq Private Market: Company-Sponsored LiquidityTender buybacks and company-sponsored liquidity programs: how NPM organizes transactions for employees and early investors in late-stage private companies.read →OFAC sanctions removal: asset unblocking procedureRemoving OFAC sanctions and unblocking assets: how the U.S. Treasury process works, delisting petitions and what UHNW clients must document to release frozen funds.read →PFIC and Form 8621Why foreign mutual funds, ETFs and passive holding companies can create PFIC issues for U.S. persons: Form 8621, QEF, mark-to-market and excess distributions.read →QSBS §1202 for the American founder: why timing decides everythingHow IRC §1202 excludes up to 100% of QSBS gain, what OBBBA 2025 changed (50/75/100% tiers, $15M cap, $75M asset test), stacking through non-grantor trusts, §1045, and why timing is everything for the American living abroad.read →Roth abroad: the one US wrapper that survives relocationWhy qualified Roth distributions stay tax-free in the UK under Article 17 of the US-UK treaty even after HMRC's 2025 tightening, how the FEIE kills your contribution room (and FTC fixes it), how Canada and France differ, and where §4975 breaks the Thiel play.read →Sydecar: Turnkey SPV with Fixed Pricing and No CarryFixed-price SPV with no carry: standardized documents, fast club deal launch, format limitations. Alternative to AngelList for deal leads who want to keep upside.read →U.S. person statusHow U.S. citizens, green card holders and substantial-presence residents determine U.S. tax status, treaty positions, dual-status years and Form 8854 risk.read →U.S. tax planning toolsLegal U.S. tax planning tools for Americans abroad: FEIE, foreign tax credit, totalization, entity classification, CFC/PFIC review, trusts, pre-immigration and expatriation planning.read →Upstream basis step-up: erasing built-in gain through the older generation, cross-border tooHow IRC §1014 resets the basis of inherited assets to date-of-death fair market value, why the step-up reaches a nonresident alien's foreign assets (Rev. Rul. 84-139), and where the §1014(e) one-year rule bites.read →US CFC Rules: Form 5471, Subpart F and GILTIHow U.S. persons report controlled foreign corporations, Subpart F income, GILTI, Form 5471, Form 8992, check-the-box planning and entity reporting.read →US Expatriation and Exit TaxA practical guide to U.S. expatriation, long-term green card termination, covered expatriate status, Form 8854, exit tax and five-year compliance certification.read →US Foreign Entity Forms: 8865, 8858 and 926A practical map for U.S. persons reporting foreign partnerships, disregarded entities, branches and transfers to foreign corporations on Forms 8865, 8858 and 926.read →US Tax Controls for Family OfficesA practical operating model for U.S. persons, families and founders managing worldwide tax reporting, FATCA, FBAR, CFC, PFIC, trusts and advisor workflow.read →US Tax Enforcement and Offshore CleanupHow U.S. persons approach FATCA data, FBAR, Form 8938, late international forms, streamlined procedures, voluntary disclosure, passport risk and cleanup strategy.read →US Tax on Worldwide IncomeWhat U.S. citizens and resident aliens report annually: Form 1040, foreign salary, self-employment, crypto, rentals, pensions, foreign taxes, FBAR and foreign entities.read →
library
companies & funds
Companies, funds, SPVs, holdings and investment vehicles in key jurisdictions.
Cook Islands trust + Nevis LLC: a procedural fortress, not secrecyHow a Cook Islands trust over a Nevis LLC works: charging order, beyond-reasonable-doubt, a three-year sunset and phantom income as procedural barriers. Why it is asset protection, not a tax scheme, and where the contempt line runs.read →Delaware LP for Funds: GP/LP, Carry, and Blocker StructuresFund structured as Delaware limited partnership: GP and LP roles, pass-through taxation and Schedule K-1, carried interest and §1061 rule, blocker corporations for foreign and tax-exempt investors.read →Delaware Series LLC fundThe Delaware Series LLC as a fund and investment-structuring tool: segregated series, liability ring-fencing, and where it fits for US private-capital vehicles.read →Intestate Succession in the USA: Intestacy, Elective Share, and PlanningHow inheritance is divided without a will in the USA: probate and state formulas, no forced share for children, spousal elective share, federal estate tax ($15M / 40%), and the $60K trap for non-residents.read →US Estate Tax: The US-Situs Trap for Non-ResidentsNon-residents face only a $60,000 estate tax exemption on US-situs assets (US stocks, real estate), with rates up to 40%. How the trap works and treaty relief.read →US LLC (Wyoming and Delaware) for Non-Residents: Disregarded Entity, ECI and Form 5472When a US LLC pays no federal tax, what ECI and ETBUS mean, why Form 5472 is required with a $25,000 penalty, and how Wyoming differs from Delaware for non-residents.read →Why a South Dakota dynasty trust does not save the American living abroadA South Dakota dynasty trust for an American who becomes UK-resident: how the Settlements Code, ToAA and s.86/s.87 TCGA collapse deferral, and how residence-based IHT from 6 April 2025 pulls trust assets into relevant property — and what the trust still delivers.read →Wyoming DAO LLC and DUNA: Legal Wrappers for Decentralized OrganizationsWyoming pioneered DAO legal status: DAO LLC since 2021 and Decentralized Unincorporated Nonprofit Association (DUNA) since July 2024—structure, taxes, and limitations.read →
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residency & citizenship
Residency and citizenship: Spain Digital Nomad, Beckham regime, Andorra, Monaco and Singapore PR.
EB-1A: the Extraordinary-Ability Green Card Without an EmployerEB-1A is the only green card needing no employer and no investment: 3 of 10 criteria, the Kazarian two-step, 45-day premium processing, family included, India/China backlogs and the tax price of the status.read →EB-5: the Investor Green Card From $800,000How EB-5 works after the 2022 reform: $800,000 into a TEA project or $1.05m, 10 jobs, regional centers, the queue-free rural set-aside, concurrent filing and the two real risks — project and tax.read →Grenada: Citizenship by Investment and US E-2 VisaGrenada citizenship: NTF contribution from USD 235,000 or real estate from USD 270,000, with unique access to the US E-2 investor visa.read →O-1A Visa: Extraordinary Ability as the US Entry TicketHow the O-1A visa works: 3 of 8 extraordinary-ability criteria, an employer or US agent as petitioner, premium processing in 15 business days, a 3-year status with unlimited extensions and the path to the EB-1A green card.read →Remote Notarisation: Russia, England, USA – One TouchHow remote notarisation works: Art. 44.3 and two-notary transactions in Russia, remote notarisation and e-Apostille in England, RON in the USA – and how Private.law makes it one touch.read →
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Other
Puerto Rico Banks: How the IFE Jurisdiction WorksPuerto Rico as a banking jurisdiction: IFE licenses under Act 273, 4% tax, Fedwire without FDIC, Act 44-2024 reform and sector cleanup. Profiles of Zenus, FV Bank, Arival.U.S. tax residencyA practical guide to U.S. tax residency, citizenship-based taxation, FATCA, FBAR, CFC, PFIC, trusts, family offices, cleanup and expatriation for Americans abroad.
FAQ
Does a US non-resident pay estate tax?
Yes. For US-situs assets (US-company shares, US real estate) the exemption is just $60,000 with rates up to 40% — a trap for non-residents; treaties and the right ownership structure help.
What is citizenship-based taxation?
The US taxes citizens and green-card holders on worldwide income regardless of where they live; hence FATCA, FBAR and the exit tax on expatriation.
Does a US LLC pay US tax?
A non-resident-owned LLC without ECI/ETBUS usually pays no federal income tax but must file Form 5472 ($25,000 penalty for failure). Wyoming and Delaware differ in the details.
Contact information
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