THYOR

Practice 02

Tax Advisory, Compliance & Private Client

Thyor provides US tax advisory, tax return preparation and filing, international and expatriate tax planning, state nexus analysis, tax-credit studies and tax-resolution support. Complex matters are coordinated with established legal and jurisdictional specialists where attorney privilege or local authority is required.

Why it matters

Tax judgement for businesses, owners and lives that cross borders.

Tax is rarely the decision, but it is almost always inside the decision. A business sale, an international move, a new holding structure, an expansion into a second jurisdiction, an investment vehicle for a family — each carries tax consequences that materially change the outcome and are expensive to repair after the fact.

For internationally mobile families and cross-border businesses, exposure compounds quietly. Residency, entity classification, withholding, permanent establishment and reporting obligations interact across jurisdictions in ways that local advisers, each seeing one country, do not naturally coordinate.

The firm’s role is senior tax judgement inside the commercial context: structuring before the fact, coordinating specialist advisers across jurisdictions, and keeping the tax position aligned with what the client is actually trying to do.

Recognisable situations

When to engage.

  1. 01

    A liquidity event is approaching

    A sale, recapitalisation or succession will crystallise value; the tax structure should be settled well before the term sheet.

  2. 02

    Life or business crosses a border

    Relocation, expatriation, a foreign acquisition or a new market creates overlapping obligations in two or more jurisdictions.

  3. 03

    The structure no longer fits

    Entities accumulated over time no longer match how the family or business actually operates and owns.

  4. 04

    A family office needs coordination

    Multiple advisers, entities and jurisdictions require one senior point of tax oversight and orchestration.

  5. 05

    A transaction needs tax diligence

    Buy-side or sell-side, the tax exposures and structuring options must be understood before price and terms are final.

  6. 06

    Cross-border operations raise questions

    Transfer of functions, assets or people across jurisdictions creates permanent-establishment and withholding questions that need senior answers.

Scope

Work configured around the decision.

Advisory & planning

  • Federal, state and local tax planning
  • Entity and ownership structure
  • Business-owner and private-client tax strategy
  • Tax policy and economic analysis

Compliance & filing

  • Business and individual tax return preparation
  • International information reporting
  • Expatriate and internationally mobile individual filings
  • Compliance oversight for complex structures

International & mobility

  • Cross-border structuring
  • Residence, relocation and exit-tax planning
  • Permanent-establishment and withholding analysis
  • Global mobility coordination

Risk, incentives & resolution

  • State nexus and apportionment studies
  • Tax-credit and incentive studies
  • Tax-risk assessment
  • IRS and tax-authority resolution short of litigation

Method

A clear sequence from fact base to execution.

  1. 01

    Map the exposure

    Residency, entities, income flows and obligations across every relevant jurisdiction — one consolidated picture before any recommendation.

  2. 02

    Clarify the objective

    What the client is trying to achieve commercially and personally; tax options are framed against that, not in the abstract.

  3. 03

    Develop structure options

    Costed, sequenced alternatives with explicit trade-offs — efficiency, risk, complexity and reversibility.

  4. 04

    Coordinate implementation

    Work with local counsel and advisers in each jurisdiction so the structure lands as designed and filings align.

  5. 05

    Maintain the position

    Periodic review as law, residency and the client’s affairs evolve; issues are addressed before they compound.

Deliverables

Work products designed to support an actual decision.

  • Cross-border exposure maps
  • Entity and holding-structure options papers
  • Transaction tax analyses and diligence reports
  • Pre-liquidity-event structuring plans
  • Family office tax coordination frameworks
  • Jurisdiction-by-jurisdiction obligation calendars
  • Tax risk registers and remediation plans
  • Tax return preparation and filing calendars
  • State nexus and apportionment studies
  • Tax-credit study memoranda
  • Tax-resolution action plans

Next step

Discuss a cross-border tax matter

Sensitive matters may be described at a high level. Scope and confidentiality are agreed before detailed information is exchanged.

Discuss a Situation