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.
Agentic Payments: Protocols and Liability When an AI Agent PaysAP2, ACP, x402, Visa TAP and Mastercard Agent Pay: how mandates and Know Your Agent work — and who is liable when an AI agent initiates a payment.read →Airwallex: business neobank for multi-currency accountsAirwallex is a business neobank for multi-currency accounts, cards, payment acceptance, API payouts, safeguarding and sanctions screening for Russian profiles.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 →Arta Finance: Investment Platform for Accredited InvestorsArta Finance is an investment platform for accredited investors operating through an SEC-registered adviser in the US and a MAS-licensed company in Singapore. Private markets, managed portfolios, structured products, AI tools, fees and eligibility.read →Augustus Bank: The AI-Era Clearing Bank for Global FintechsAugustus (ex-Ivy): OCC conditional approval for a US clearing bank built around stablecoins. B2B-only, API-first, EUR clearing live, USD pending licence.read →Avit: Tokenised Bank Deposit from Custodia and VantageAvit is a tokenised bank-deposit structure developed by Custodia Bank and Vantage Bank Texas. SPDI and FDIC bank roles, issuance and redemption, US–Mexico settlement, Hazel Network, master-account litigation and limitations.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 a Licensed Operator: How MSBs, MSOs, EMIs and PSPs Open and Keep AccountsThe operator account stack, why banks refuse, the 2026 provider map, CASS 15 from 7 May 2026 and a 90-day notice right from 28 April 2026.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 →Booking Centre: Account Jurisdiction and Applicable RulesA booking centre sets the governing law, regulator, insolvency ranking, transaction taxes and CRS reporting. Why the location is a separate decision from the bank.read →Bridge (Stripe): Stablecoin Infrastructure and Preliminary OCC ApprovalBridge is Stripe's infrastructure for stablecoin payments, issuance, wallets and cards. Stripe acquisition, preliminary conditional OCC approval, products, onboarding and current limitations.read →BVNK: Stablecoin Payment Infrastructure for BusinessesBVNK provides infrastructure for cross-border payments through stablecoins and bank rails. Products, licences, onboarding, pricing model and the acquisition by Mastercard.read →CBDCs in 2026: the Digital Euro, the Digital Ruble and the US ForkThe digital euro pilot in 2027, a mandatory digital ruble from 1 September 2026 and a US CBDC ban: what the CBDC map means for banks and private clients.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 →Compound Planning: the $5 Billion Digital Family OfficeAn SEC-registered RIA with $5 billion in AUM growing 75% a year: how Compound Planning's digital multi-family office works — model, fees, who it serves.read →Conduit: B2B Payments Through StablecoinsConduit provides B2B cross-border payments through bank rails, virtual accounts and stablecoins. Routes in Latin America and Africa, pricing, timing, KYB, partner infrastructure and liquidity limitations.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 →Farther: SEC-Registered RIA and Wealth PlatformFarther is an SEC-registered investment adviser and wealth platform. Services, regulatory and recruited asset metrics, fees, custody at Fidelity, Schwab, Pershing and Apex, client eligibility and conflicts.read →Fed Payment Accounts: the Skinny Master Account and the End of the Sponsor-Bank MonopolyThe Fed's 20 May 2026 NPRM: direct Fedwire and FedNow access for trusts and SPDIs — a $1bn cap, zero interest, no ACH. What it breaks in BaaS.read →FinCEN MSB in the US: the Registration That Does Not Replace a State LicenceMSB status attaches by activity, not office: Form 107 in 180 days, an AML programme in 90 — and a missing state licence is a federal crime under 18 U.S.C. 1960.read →Flex (flex.one): Business Accounts, Cards and Payments Through Partner BanksFlex is a financial technology platform for US businesses, not a bank. Business accounts, debit, charge and credit cards, international payments, partner banks, FDIC sweep coverage, pricing, stablecoin features and onboarding limits.read →GENIUS Act: the US Federal Regime for Payment StablecoinsThree PPSI issuer tracks, 1:1 reserves, the yield ban, the January 18, 2027 start date and the July 18, 2028 cutoff — how the US federal stablecoin regime works.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 →Industrial Loan Companies: Banking Charters for Non-Financial GroupsIndustrial loan companies are state banking charters that may be owned by certain non-financial groups. Legal basis, FDIC conditions, approvals for Ford, GM, Edward Jones and Stellantis, and alternatives.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 →Klarna Bank USA: Application for a Utah Industrial BankKlarna Bank USA is a pending application for a Utah industrial bank. Existing US products through WebBank, proposed deposits and BNPL funding, FDIC requirements and limitations before approval.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 →Money Transmitter Licenses in the US: Fifty Licenses Instead of OneNo federal money transmission license exists in the US: MTMA implementation, state exemptions, bond and capital rules, crypto regimes and 18 U.S.C. 1960.read →Morgan Stanley Digital Trust: preliminary OCC approval for crypto custodyMorgan Stanley Digital Trust received preliminary conditional OCC approval for a national trust bank focused on digital-asset custody and related services. Current E*TRADE infrastructure, proposed functions, pricing and launch limitations.read →Nubank, N.A.: Conditional Approval for a US National Bank CharterNubank, N.A. received conditional OCC approval for a de novo national bank. Conditions before launch, proposed products, links to Nubank's Latin American business, FDIC and current limitations.read →NYDFS: BitLicense and the New York Trust Charter — Two Doors Into US Crypto26 BitLicenses and 13 trust charters as of August 2026, an eight-coin Greenlist, 226.5m in penalties and the OCC charter migration reshaping New York after the GENIUS Act.read →OakNorth: UK Commercial Bank and US Bank AcquisitionOakNorth is a UK commercial bank focused on growing businesses. Lending, deposits, FSCS, the ONCI platform and the acquisition of Community Unity Bank in the US, including onboarding and regulatory conditions.read →PayFac, ISO and Merchant of Record: Who Carries the Risk in AcquiringVisa Rules of 18 April 2026: the USD 1m sub-merchant threshold, VAMP at 150 bps from 1 April, assessments to USD 250,000, and where a platform's licence actually starts.read →PayoneerPayoneer is a public fintech for marketplace revenue collection and cross-border payouts. Account features, limits, and suitable company profiles.read →PayPal Bank: Application for a Utah Industrial BankPayPal Bank is a pending application for an industrial bank in Utah and FDIC insurance. Current products through Synchrony, WebBank and Paxos, proposed deposits and lending, PYUSD and limitations before approval.read →Ramp: Corporate Cards, Spend Management and TreasuryRamp is a financial platform for US companies offering corporate cards, spend management, bill pay, procurement and treasury through partner banks and brokerage infrastructure. Pricing, FDIC sweep, money-market funds, AI tools and onboarding.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 →Sanctions Screening at a Financial Operator: The Discipline That Holds Payments TogetherThe EU's 21st package of 23 July 2026, OFAC's sham-transactions guidance and a USD 275m penalty: how sanctions screening works and why payments stall.read →Slash: Business Banking for Specialised IndustriesSlash is a US financial platform for businesses in specialised and higher-risk industries. Business accounts, corporate and virtual cards, Global USD Account, stablecoin functions, partner banks, pricing, onboarding and limitations.read →SoFi Bank and SoFiUSD: Banking, Crypto Trading and StablecoinSoFi Bank and SoFiUSD: national bank charter, banking and investment products, crypto trading, stablecoin reserves, FDIC, pricing and product limitations.read →Sony Connectia Trust: Preliminary OCC Approval for a National Trust CharterSony Connectia Trust, N.A. received preliminary conditional OCC approval for a proposed dollar-stablecoin trust bank. Group structure, Bastion, reserves, possible use cases and limitations before launch.read →The Digital Dollar in Four Legal Forms: Deposit Tokens, Stablecoins, EMTs and Tokenised FundsDeposit tokens, payment stablecoins, MiCA e-money tokens and tokenised money market funds: legal nature, holder protection and balance-sheet risks — in one table.read →The OCC National Trust Charter: a Bank Without Deposits for Crypto and FintechFiduciary powers, preemption of some 50 state MTLs and life without FDIC: how Ripple, Circle and Morgan Stanley take a national trust charter — and what it buys.read →Travel Rule: Two Regimes, Divergent Thresholds and the Data That Travels With a TransferTwo Travel Rules, not one: a zero threshold in the EU since Dec 2024, £800 in the UK since June 2026, USD 3,000 in the US since 1996, zero in Korea from Feb 2027.read →US MSB Registration and Money Transmitter Licences: FinCEN plus the State MapFinCEN MSB registration is not a licence: a US payments business needs MTLs in up to 49 states. The MTMA map, exemptions, timelines, budgets and federal alternatives.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 →Zenus Bank: US Digital Bank for Non-Residents with an IFE LicenseZenus Bank (Puerto Rico, IFE-061, OCIF): USD accounts for non-US residents, remote onboarding, Visa Infinite debit card. Fees, limits, who it suits.read →Zero Hash: embedded crypto, custody and settlement infrastructureZero Hash provides embedded crypto trading, custody, stablecoin payments, settlement and tokenisation for brokers, banks and fintechs. Licences, end-client agreements, pricing, protections and OCC application status.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 →Article 17 of the OECD Model: Tax Where You PerformWithholding on performers and athletes: 20% in the UK, 30% in the US, treaty thresholds of $10,000–20,000, event exemptions and the Monaco and UAE dead end.read →Borrow Against a Collection or Sell: Tax, Cost and RiskInterest on art loans is non-deductible under §163(h), with no carryforward. Break-even is 5 years versus 7.5 for an SBLOC. Maths, §68 from 2026, collateral.read →Capital Gains on Art and Collectibles by CountryUS 28% plus NIIT, Germany nil after a year and a day, France 6.5% of price, UK wasting assets, Switzerland and Italy judged on the seller's conduct.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 →Fund Secondaries: LP-Led, GP-Led and Continuation VehiclesLP-led and GP-led fund secondaries: continuation fund mechanics, status quo option, fairness opinions, conflicts of interest, and 2025-2026 market data.read →Getting Paid After You Move: Ohtani, Bonuses and RCAs4 U.S.C. § 114 and Ohtani's $680m: how a deferred payout escapes state tax, where § 409A and § 457A bite, and what the Tavares dispute with the CRA turns on.read →Golden Visas and Tax Residence: Status, Presence and Tax ExposureWhere an investor residence permit changes nothing (Portugal, Greece), where municipal registration is the trigger (Italy) and where the card itself is residency (US).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 (Payward): how the business works, Q2 2026 results, and the road to going publicHow Kraken's business works, its Q2 2026 results, and the current status of its path to going public, for investors.read →Kraken: regulation, custody and institutional servicesKraken: trading, Prime, OTC, staking and custody through Kraken Financial. Regulatory entities, Wyoming SPDI status, asset protection, onboarding and limits of public insurance disclosure.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 →NIL in 2026: Revenue Sharing, Deal Clearing and the F-1 DeadlockHouse v. NCAA: a $20.5m cap per school in 2025/26 and $21.3m in 2026/27, deal clearing from $600, self-employment tax and the F-1 deadlock for foreign athletes.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 →Pension Assets on Relocation: SIPP, QROPS, 401(k) and the Destination CountryWhat happens to pension savings when residency changes: SIPP relief, the 25% Overseas Transfer Charge, 401(k) and IRA, UK IHT from 2027, destination regimes.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 →Platform Withholding: YouTube, Twitch and TikTokHow YouTube, Twitch and TikTok withhold US tax: 30% on the US share, up to 24% without a W-8BEN, and why Russian residents lost the treaty rate in 2024.read →Private Aircraft Tax: Bonus Depreciation, VAT and Personal Use100% bonus depreciation after OBBBA, the §280F, §274 and §469 tests, 2026 SIFL rates, EU input VAT recovery and the capital goods scheme, benefit in kind across four jurisdictions.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 →Regulating Info-Products and Influencers: Advertising, Registers, LiabilityA comparison of the rules for info-products and creators: ad disclosure (FTC, CAP Code, DSA, erid), registers in Russia, Spain, Italy and the UAE, ceilings from 6% and 10% of turnover to criminal cases in Russia.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 →The OnlyFans Economy: Why the Platform Pays the VAT for EveryoneFenix International (C-695/20): the platform pays VAT on the fan's whole payment, not on its 20% cut. What is left to the creator: registration, 1099s, DAC7.read →The Total Cost of a Route: What Investors Pay on Top of the InvestmentGovernment fees, due diligence charges, agent commission, property transfer taxes and the price of exit: full cost of three routes for a family of three in 2026.read →The United States for a Foreign Athlete: 30%, CWAs and the Jock Tax30% of gross under §1441, a CWA filed 45 days before the event, jock tax on duty days, Pittsburgh's 3% struck down on 25.09.2025 and the World Cup formula.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 →Who Sees a Creator's Income: DAC7, MRDP, 1099-K and CESOPNo threshold under DAC7 for personal services, UK MRDP from 2024, the 1099-K threshold back at $20,000 and 200 transactions, CESOP from 25 payments a quarter.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 →Creator Holdco: Turning Reach into Capital§ 1221(a)(3) IRC turns the sale of a channel into ordinary income: why a creator needs a holdco, a C-corp and QSBS with a $15m cap, and how the Beast round works.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 →Family Philanthropy: Foundations, DAFs and Cross-Border GivingHow family charitable capital is structured: US private foundations vs DAFs, UK Gift Aid and the 10% IHT threshold, the Stiftung, and cross-border giving.read →Fund Finance: Subscription Lines and NAV FacilitiesFund-level debt explained: subscription lines on uncalled commitments, NAV facilities on the portfolio, hybrids and GP lines. IRR impact and LP checklist.read →Fund LPA: Clawback, LPAC and GP RemovalHow an LPA protects LPs: clawback and escrow, recycling limits, LPAC powers, for-cause and no-fault removal, key person events and ILPA standards.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 →Personal Use of Corporate Assets: Benefit-in-Kind for Aircraft, Yachts and PropertyHow personal use of a corporate jet, yacht or villa is taxed: US SIFL, the UK 20% rule, French valeur réelle, Spain's TEAC criterion and Russian art. 211.read →Private Museum and Charitable Foundation: Collection Ownership and the FMV DeductionPrivate operating foundation §4942(j)(3): full fair market value deduction, 30% AGI ceiling, related use, self-dealing under §4941 and the 0.5% floor from 2026.read →Situs of Movable Assets: Aircraft, Yachts and CollectionsWhere a jet, yacht or painting sits for inheritance tax: the US $60,000 threshold, the UK long-term residence test, French assiette matérielle, treaties.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.
Athlete Visas and Residence Permits: A Map of the RoutesP-1A and O-1A in the US, premium processing at $2,965 from 1 March 2026, the FA's June 2026 GBE changes, carte talent, § 22 BeschV and the UAE Golden Visa.read →Caribbean CBI Under Ultimatum: the EU's 2028 Deadline and US Entry RestrictionsThe EU wants Caribbean CBI programmes wound down by 1 June 2028 or Schengen goes; the US already restricts Antigua and Dominica. What issued passports face.read →Due Diligence in Investment Migration: What Is Checked and Why Files FailHow vetting works in residence and citizenship by investment: the six 2024 principles, the ECCIRA agreement, the AMLR from 10 July 2027 and refusal grounds.read →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 →Five Ways to Buy In: Contribution, Fund, Property, Business, DepositContribution, fund, property, business and deposit: 2026 thresholds — €250k in Hungary, €500k in Portugal, $800k for EB-5 — and what each model really costs.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 →Migration Routes for Business OwnersL-1 and EB-1C, the UK Expansion Worker at £52,500, Japan's ¥30m Business Manager, Spain's Ley 14/2013, Canada's paused SUV and the Gulf RHQ regimes compared.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 →O-1B: The American Visa for Influencers and CreatorsSix criteria under 8 CFR 214.2(o)(3)(iv), 2026 fees (I-129 $1,055, premium $2,965), the consultation letter, social media vetting from 30 March 2026 and EB-1A.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 →Retroactive Reform: What Happens to Your Status When a Programme ClosesIreland 2023, the UK 2022, Spain 2025, Malta after C-181/23, Portugal 2026 and EB-5 to 30.09.2026: how reforms hit status and the road to a passport.read →Talent Instead of Capital: How Credentials Replace the InvestmentEB-1A, O-1A, Global Talent, NIV 858 and France's talent permit: which achievements count instead of an investment, what it costs and how long it takes in 2026.read →
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Other
Fintech: licences, banking infrastructure, payments and stablecoinsFintech regulation and operating infrastructure: licence selection, banking and safeguarding, acquiring, sanctions controls, stablecoins, crypto custody and regional regulatory regimes.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.The Professional Athlete: Money, Visas and Tax — Cluster MapCluster map for the professional athlete: 183 days and centre of interests, OECD Article 17, 20% in the UK and 30% in the US, jock tax, image rights, visas.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.US Financial and Crypto Licenses: Three Axes of Choice — Which Door You NeedThree axes decide a US regime: federal or state, deposit status, and Fed settlement access. Charters, ILCs, SPDIs, MTLs and the GENIUS Act from 18 Jan 2027.
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.
If you have questions or need a consultation, our experts will be glad to help.