Expanding investments across multiple countries can create incredible opportunities, but it also brings new layers of complexity—especially when it comes to taxes. I’ve worked with families who have successfully diversified their holdings internationally, only to realize that cross-border tax planning is just as important as choosing the right investments. Without careful planning, families can face unexpected tax liabilities, compliance risks, and inefficient capital flows.
When families expand into new markets, the focus is often on financial growth - accessing new assets, increasing diversification, or establishing a presence in key regions. However, each country has its own tax laws, and failing to integrate tax planning into the overall strategy can lead to unnecessary burdens, including double taxation or complex reporting obligations.
It’s also important to consider the individual tax situations of family members. I’ve seen cases where one member moves abroad for education, another relocates for business, and suddenly, overlapping tax exposures arise. Mapping out each person’s residency status, potential tax triggers, and inheritance tax obligations helps ensure a coordinated, compliant, and tax-efficient wealth plan.
One of the most powerful tools available in cross-border tax planning is bilateral tax treaties. These agreements are designed to reduce or eliminate double taxation on income, dividends, interest, and royalties. When structured correctly, tax treaties can help lower withholding taxes, improve cash flow efficiency, and simplify cross-border financial transactions.
Some families establish holding companies in jurisdictions with strong treaty networks to optimize tax efficiency. However, authorities are increasingly scrutinizing entities that lack real economic substance. To maintain compliance, I always advise families to ensure that any offshore business structures have legitimate operations, meaning local staff, a real office, and active decision-making within the jurisdiction. Not only does this meet regulatory requirements, but it also strengthens the credibility of the family’s international business footprint.
Even if a family invests through offshore entities, at some point, those profits need to be distributed, either reinvested elsewhere or transferred to individual beneficiaries. The challenge is structuring this movement of funds in the most tax-efficient way possible.
Many families use intermediary holding companies in tax-friendly jurisdictions to reduce withholding taxes on dividends and interest payments. At the same time, it’s critical to be aware of Controlled Foreign Corporation (CFC) rules, which can subject passive foreign income to immediate taxation in the family’s home country. Balancing CFC regulations, local corporate tax rates, and anti-avoidance provisions ensures that families maintain compliance while minimizing unnecessary tax exposure.
For families relocating to a new country, tax exposure can shift significantly, sometimes overnight. Many jurisdictions tax worldwide income once residency is established, which is why pre-immigration tax planning is essential.
I always encourage families to evaluate whether they should trigger capital gains on appreciated assets before moving, potentially locking in lower tax rates in their current jurisdiction. Another strategy involves transferring intellectual property or intangible assets into an appropriate holding structure before changing residency, ensuring that any future licensing income is not automatically subject to the new country’s higher tax rates. The key is to plan early; last-minute transfers often attract scrutiny, and authorities are quick to challenge transactions that appear solely tax-driven.
Certain countries offer special tax regimes for non-domiciled individuals, allowing them to pay tax only on income that is sourced within the country or remitted there. The United Kingdom’s remittance basis is a well-known example, and I’ve seen families take advantage of this status to limit their global tax exposure.
However, non-domiciled regimes require careful management. Maintaining separate accounts for pre-move and post-move income is crucial, as is keeping clear records of remittances to avoid triggering unexpected tax liabilities. These regimes often come with time limits, increasing fees, or strict renewal requirements, so families must continuously reassess their eligibility to avoid losing the tax benefits they originally planned for.
I recently worked with a family whose members were spread across three continents, each with property and business interests in different countries. To optimize their tax position, they established a holding company in a treaty-friendly jurisdiction, allowing dividends from international businesses to be routed efficiently. One family member also took advantage of a non-domiciled tax regime after restructuring assets into a trust before relocating.
By combining tax treaty benefits, local substance requirements, and careful pre-immigration planning, they minimized withholding taxes, complied with CFC rules, and ensured that their international wealth transfers were efficient and legally sound. The key to their success was continuous coordination between tax advisors and legal professionals to adapt to evolving regulations.
Cross-border tax planning isn’t something families can set and forget. Tax treaties evolve, governments introduce new anti-avoidance measures, and international compliance standards become stricter over time. Even a well-designed tax structure can lose its effectiveness if it isn’t reviewed regularly.
I always recommend that families establish strong governance protocols, including detailed recordkeeping, consolidated reporting, and periodic audits of all international entities. Collaboration with global tax advisors, trust experts, and compliance specialists is essential. Using modern technology solutions to track international assets and transactions also helps ensure that everything remains transparent and well-documented.
Cross-border tax planning is most effective when it balances compliance with long-term financial goals. By leveraging tax treaties, structuring repatriation efficiently, planning ahead for relocations, and utilizing non-domiciled tax regimes where appropriate, families can significantly reduce their tax burden while ensuring financial flexibility.
The key is staying proactive. What works today may need adjustments tomorrow due to shifting regulations or changes in family circumstances. Regular reviews, strong governance, and a coordinated approach keep cross-border tax strategies effective. With the right planning, families can focus less on tax hurdles and more on growing, preserving, and enjoying their wealth across generations.
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Ellie Perlman is the founder and CEO of Blue Lake Capital, a woman owned multifamily real estate investment firm focused on partnering with family offices and accredited investors to build and preserve generational wealth. Since its founding in 2017, Blue Lake has successfully acquired and operated multifamily assets across high-growth U.S. markets, completing $1B+ in transactions.
At Blue Lake Capital, Ellie and her team work exclusively with family offices and accredited investors, offering carefully curated investment opportunities that emphasize long-term wealth creation, stability, and risk-adjusted returns. A defining aspect of Blue Lake’s investment strategy is its integration of advanced AI-driven analytics and data science into the entire lifecycle of acquisitions and asset management. By leveraging cutting-edge technology, the firm executes data-driven forecasting on market trends, asset performance, and tenant behavior, ensuring strategic decision-making and optimized returns.
In addition to leading Blue Lake Capital, Ellie is a frequent contributor to Forbes.
Ellie began her career as a commercial real estate attorney, structuring and negotiating complex transactions for one of Israel’s leading development firms. She later transitioned into property management, overseeing over $100M in assets for Israel’s largest energy company.
Ellie holds a Master’s in Law from Bar-Ilan University in Israel and an MBA from MIT Sloan School of Management.
You can learn more about Blue Lake Capital and Ellie Perlman at www.bluelake-capital.com.
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