US Tax Consulting

in Singapore, Taiwan and Hong Kong

Renounce US citizenship or surrender green cards while minimizing or avoiding adverse US tax consequences

Come into compliance with the IRS through the Streamlined Filing Compliance Procedures or Voluntary Disclosure

Establish Foreign Grantor Trusts to reduce US federal estate tax for your US person beneficiaries.

Handle IRS audits and appeals

This includes preparing IRS appeals petitions, drafting reasonable cause statements, and resolving IRS notices and letters.

Our expertise

Ivan (Yi Kuan) Lu and Timmoney Ng are both US international tax lawyers at Charles Russell Speechlys’ Singapore office.

Ivan

helps high-net-worth individuals on the below

01

Restructuring and establishing trusts

This includes Foreign Grantor Trusts, Foreign Non-Grantor Trusts, Intentionally Defective Grantor Trusts, and US standby trusts.

02

Mitigating US estate tax exposure

This includes navigating the throwback tax under IRC Sections 665 & 666 and the Passive Foreign Investment Company (PFIC)/Controlled Foreign Corporation (CFC) attribution rules applicable to the US beneficiaries of Foreign Non-Grantor Trusts.

03

Planning for immigration to or departure from the United States

For example, using the treaty-tie breaker rules or the closer connection test to end US income tax residency.

Tim

01

Solves complex tax issues related to the Passive Foreign Investment Company (PFIC) and Controlled Foreign Corporation (CFC) rules

This involves structuring to prevent PFIC classification and to reduce the tax on net CFC tested income (aka Global Intangible Low-Taxed Income or "GILTI").

02

Structures funds to accommodate the US tax requirements of limited partners (i.e., investors) and general partners.

For example, making check-the-box elections (Form 8832) to enable flow-through tax treatment for US taxable investors/GPs , preventing Unrelated Business Taxable Income (UBTI) for US tax exempt investors , and managing commercial activity attribution to sovereign wealth funds and other Section 892 investors.

03

Creates tax-efficient solutions for: US parent companies with non-US subsidiaries, non-US parent companies with US operations, and investment in US real property

This involves structuring to: (1) avoid creating a US tax nexus (aka "engaging in a US trade or business"), (2) mitigate US withholding tax under Foreign Investment in Real Property Tax Act (FIRPTA) and the branch profits tax under Section 884, or (3) prevent double taxation on the sale of US real property held through foreign entities.

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Trusted by the world’s top companies

We are regularly speakers at, have worked with, or regularly receive referrals from public banks, accounting firms, and trust companies.

Why us?

We’re US Tax Nerds

We embrace the wisdom of Judge Learned Hand: “Anyone may so arrange his affairs that his taxes shall be as low as possible; he is not bound to choose that pattern which will best pay the Treasury, there is not even a patriotic duty to increase one’s taxes.”

Our passion lies not just in understanding US tax law, but in applying our extensive technical knowledge and experience to help our clients achieve optimal tax efficiency.

Although based in Asia, we are dedicated to staying at the forefront of U.S. tax developments.
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We make annual trips to the US to attend tax conferences and seminars, ensuring we are always up-to-date with the latest changes in tax laws and regulations.

We were both the top tax law students of our Juris Doctor programs: Tim won the Fenwick Prize at Berkeley (awarded to the top tax law student of the graduating class at Berkeley) and Ivan won the Bruce I. Hochman Award at UCLA (awarded to the top tax law student of the graduating class at UCLA).

Localized Presence in Asia

Strategically based in Singapore, with frequent travels to Taiwan and Hong Kong, we offer comprehensive and tailored tax solutions to clients across the Asia-Pacific region.

Our deep understanding of local legal landscapes, combined with our expertise in US tax law, enable us to address and resolve the unique challenges faced by clients in Asia.

Our localized presence ensures prompt and responsive service, eliminating the need for early morning or late-night calls to accommodate US-based practitioners.

We’re fluent in Mandarin, Korean, and Japanese

Our team at Charles Russell Speechlys LLP is fluent in English, Mandarin, Cantonese, Korean, and Japanese. This linguistic versatility allows us to communicate complex US tax concepts with clarity and precision, ensuring nothing is lost in translation.Additionally, we can provide work products in Chinese, making it easier for our clients to fully understand and benefit from our services.

Hello! We’re Ivan and Tim—US international tax lawyers based in Singapore with frequent travels to Taiwan and Hong Kong. Our mission is to make US tax rules easier to understand for individuals and businesses abroad.

We’re always happy to chat about US taxes. If you have any US tax queries, please schedule an obligation-free call with us below.

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