Practical guidance on international tax planning, cross-border wealth preservation, and global compliance — written for high-net-worth individuals and families who need clarity, not jargon.
Orientación práctica sobre planificación fiscal internacional, preservación de patrimonio transfronterizo y cumplimiento global — escrita para individuos y familias de alto patrimonio que necesitan claridad, no jerga.
There is a specific moment — one that most EB-5 investors never think about until it has already passed — when the entire architecture of their financial life shifts. It is not the day they receive their green card. It is the day their status changes in the eyes of the U.S. tax system. And on that day, the rules governing every account, every asset, every trust, and every business interest they hold — anywhere in the world — change permanently.
For many clients, the decision to relinquish U.S. citizenship or abandon a long-term green card has been years in the making — the culmination of a life that has grown larger than any single country's tax system was designed to accommodate. That decision is irreversible. And irreversibility is exactly why the planning that precedes it must be as thorough as any financial decision a person will ever make.
Money moves across borders the same way families do — quietly, purposefully, and often without anyone thinking carefully about the rules that apply on the other side. The U.S. reporting obligations that attach to foreign financial connections are among the most misunderstood — and most consequential — in the entire Internal Revenue Code. This is what you need to know.
My own family spans four countries. When I think about what it means to preserve wealth across generations, I am not thinking abstractly — I am thinking about the very real complexity of a life that does not fit inside a single legal system, and about the families I serve navigating that same complexity with far more at stake.
There is a particular kind of IRS examination unlike any other in its scope, complexity, and potential consequences — the international examination. The IRS has been building its capacity to conduct these for two decades. The clients who fare best are not necessarily those with the cleanest returns. They are the ones whose counsel understood, from the first contact, that this is not a conversation. It is a strategic proceeding.
In 2021, El Salvador became the first country to adopt Bitcoin as legal tender. My maternal family is from El Salvador — so I have watched this unfold with the attention of someone who understands both what it means for a small country to make that kind of bet, and what it means for U.S. taxpayers, cross-border investors, and global families navigating digital assets in a world where the rules are still being written.
Schedule a confidential consultation with Jamihlia F. Johnson, Esq. and get clarity on your cross-border tax position.
Agende una consulta confidencial con Jamihlia F. Johnson, Esq. y obtenga claridad sobre su posición fiscal transfronteriza.
Schedule a Consultation — $500 Agendar Consulta — $500