
Key takeaways
- 01Residency, domicile and citizenship are distinct tests, and each can trigger tax obligations independently.
- 02Trust structures that work in one jurisdiction can create punitive outcomes in another.
- 03A single coordinating advisor across jurisdictions is essential for internationally mobile families.
A growing share of the families we serve have members living in more than one country. Children study and settle abroad; principals divide time between homes; operating businesses expand internationally. Each of these moves can quietly change a family's tax position.
Three tests, not one
Residency, domicile and citizenship are assessed differently across jurisdictions, and each can independently create income, gift or estate tax exposure. The United States, unusually, taxes its citizens on worldwide income regardless of where they live — which shapes planning for every family with an American member.
Where structures break down
- Foreign trusts with US beneficiaries can generate complex reporting and punitive tax on accumulated income.
- Investment funds that are efficient domestically may be treated as passive foreign investment companies abroad.
- Estate plans drafted under one legal system may not be recognised in another.
Coordinating across borders
We act as the coordinating hub between a family's advisors in each jurisdiction, maintaining a single map of residency, assets, entities and obligations. Before any move — a child relocating, a property purchase, a business expansion — we model the consequences across every affected regime.
“For international families, the most expensive tax problems are the ones nobody was responsible for noticing.”

About the author
Alex Tanaka
Head of Tax & Estate
Estate attorney turned strategist, coordinating trust and entity structures across jurisdictions.
Insights are provided for informational purposes only and do not constitute investment, tax or legal advice. Opinions reflect the judgment of the authors as of the date of publication and are subject to change without notice.
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