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.
banks & neobanks
- Airwallex: business neobank for multi-currency accounts
- BaaS and Sponsor Bank: Banking Product Without a Banking License
- BaaS middleware: Unit, Treasury Prime, Synctera
- BNY (Bank of New York Mellon): World's Largest Custodian, BNY Wealth and Pershing
- Equals Money: British account for Americans and companies with significant FX demand
- Goldman Sachs Private Wealth Management UK: $10M+ Entry and Institutional UHNW
- HEVN: Cross-Border Business Banking API Platform – Local EU/US/UAE Accounts, Stablecoins & Payroll
- J.P. Morgan Private Bank UK: US-origin UHNW in London — investment banking expertise and £10M+ entry
- J.P. Morgan: Corporate & Investment Bank and Private Bank of JPMorgan Chase
- Mercury
- Payoneer
- Rent-a-Bank and True Lender: Whose Rate Backs the Loan
- US Sponsor Banks: Partner Banks for Fintech and BaaS
- Wise Business
tax & investments
- Anchorage Digital: Crypto Custody Under Federal Banking License
- AngelList: How a Family Office Runs "Club" Deals
- Carta: Cap Table Management, Fund Administration, and a Data Privacy Lesson
- Coinbase Prime: Crypto Prime Brokerage of a Public Company
- Enforcement and cleanup
- Expatriation and exit tax
- Family office tax controls
- FATCA, FBAR and Form 8938
- FEIE and foreign tax credit
- Fireblocks: The Infrastructure Behind Everyone Else
- Foreign entity forms
- Foreign trusts and Form 3520
- Forge Global: Full-Stack Secondary Market—Now Under Schwab
- Hiive: Order Book for Private Company Shares
- How National Security Review works
- How to invest in unicorn shares on the secondary market
- iCapital: The Alternative Investment "Plumbing" You Don't See
- Kraken: Crypto Exchange for Institutional Clients and Private Wealth
- Masterworks: How to Buy a Share in Banksy Without Buying the Painting
- Nasdaq Private Market: Company-Sponsored Liquidity
- OFAC sanctions removal: asset unblocking procedure
- PFIC and Form 8621
- Sydecar: Turnkey SPV with Fixed Pricing and No Carry
- U.S. CFC rules
- U.S. person status
- U.S. tax planning tools
- Worldwide income
companies & funds
- Delaware Series LLC fund
- Fronting Carriers: State National, Transverse, Clear Blue, Accredited
- New Zealand Foreign Trust: Zero Tax on Foreign Income and IRD Registration
- US Estate Tax: The US-Situs Trap for Non-Residents
- US LLC (Wyoming and Delaware) for Non-Residents: Disregarded Entity, ECI and Form 5472
- Wyoming DAO LLC and DUNA: Legal Wrappers for Decentralized Organizations
residency & citizenship
Other
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
If you have questions or need a consultation, our experts will be glad to help.