An individual planning to become a U.S. tax resident should consider pre-immigration tax planning techniques to minimize U.S. income and estate tax exposure. With advanced planning, foreigners can spend considerable time in the United States on non-immigrant visas and avoid U.S. worldwide taxation and reporting.


A list of several planning options are listed immediately below:

  • Accelerate gains on appreciated foreign assets;
  • Defer losses on depreciated foreign assets;
  • Accelerate foreign items of income;
  • Defer foreign deductible expenses;
  • Check-the-box elections to treat foreign entities as flow-through/disregarded entities;
  • Invest in a foreign annuity or life insurance policy; and
  • Make irrevocable gifts of foreign situs property (or U.S. intangible property) to a spouse or to a family trust.

Pre Immigration Tax Planning