Asset Structuring Before Major Transitions: Why Timing Matters for International Families and Business Owners
Miami has become a magnet for global wealth, and places like Key Biscayne are home to business owners, investors, and families with ties across borders. Whether you’re expanding operations, preparing for U.S. tax residency, or simply thinking long-term about how your assets are held, one thing is clear:
Structure matters. And timing is critical.
What Does Asset Structuring Actually Mean?
Asset structuring isn’t just about saving taxes — it’s about protecting what you’ve built, minimizing exposure, and aligning your legal entities and holdings with your goals.
It can include:
• Setting up or restructuring LLCs, holding companies, or corporate groups
• Creating or modifying trusts (revocable, irrevocable, domestic, or foreign)
• Reviewing ownership of real estate, IP, or private equity positions
• Planning for succession, gifting, or sale of interests
A Key Moment: Pre-Immigration Planning
If you or a family member are preparing to become a U.S. tax resident (often by meeting the substantial presence test), you may trigger full U.S. taxation on worldwide income and reporting on foreign entities.
That’s where pre-immigration planning comes in.
Done correctly — before you cross the residency threshold — you may be able to:
• Step up the tax basis of certain assets
• Reorganize ownership of offshore companies to avoid CFC or PFICissues
• Plan trust distributions to avoid the Throwback Rule
• Prepare for IRS foreign reporting (Forms 3520, 5471, 8938…)
Why This Matters in Miami
In communities like Key Biscayne, these transitions happen more than people realize — children moving here for school, families relocating for lifestyle or security, or business interests expanding into the U.S. market.
But few take the time to coordinate legal, tax, and structural planning in advance.That’s where issues arise.
How We Help
At Recalde Law Firm, P.A., we work with families, founders, and private clients in Miami and abroad to quietly prepare for major transitions — whether that’s immigration, business sale, or next-generation planning.
We collaborate with your existing tax and financial advisors or help you build the right team.
Next Step
If you’re considering a change in tax residency, exploring a new business structure, or simply want a legal review of how your holdings are organized, we’re happy to talk.
It’s not about complexity. It’s about clarity.
