Pre-Immigration
The lowest-cost point is before residency
Before U.S. residency begins, sales, restructurings or entity elections can reset basis to current value; after the start date the same steps are taxable.
Family Tax Advisory · HNW Families · Cross-Border Assets · Succession
For cross-border families,
sequence determines the outcome.
We advise families with assets in the United States and China on planning before a change in residency, the U.S. estate exposure of the older generation, the U.S. classification of foreign trusts and companies, and succession — implemented with counsel in both jurisdictions.
Email us first
Already in touch? Book · $599
By email inquiry first · 30 minutes · in person in Irvine available · credited upon engagement
Email is for initial communication only. Sensitive documents are not sent by ordinary email; the channel is arranged separately, with an NDA where appropriate.
Our View
Cross-border outcomes turn on sequence: residency before or after dispositions, a trust before or after gifts, arrangements made during the parents' lifetimes or after. The same assets in a different order can differ by millions, and most sequences cannot be reversed.
- $60,000Estate tax exemption for U.S.-situs assets of nonresidents ($15,000,000 for citizens and residents)
- 40%Top federal estate tax rate above it; no U.S.–China estate tax treaty
- 75 daysFor a retroactive entity election after the grantor's death
- 5 yearsTrusts funded within five years before immigration may become grantor trusts (§679)
01How We Work
Analytical Framework
Five questions, taken in order; each answer determines whether the next is necessary.
01Status
Who is each family member under U.S. law?
Facts to establishCitizenship, green card, substantial presence, residency start dates and expected changes — parents and children separately.
DeliverableResidency map
02
Assets
What is each asset under U.S. law?
Facts to establishBy location, holding form and character: U.S.-situs assets, foreign companies (CFC / PFIC), foreign trusts, Chinese wealth products and policies.
DeliverableFamily balance sheet
03
Windows
Which steps must precede a given point?
Facts to establishBasis resets before residency, lifetime distributions and gifts, post-death election deadlines — ranked by irreversibility.
DeliverablePre-immigration memorandum
04
Structure
Which holding form works under both systems?
Facts to establishDirect, corporate or trust ownership compared on estate tax, basis, annual reporting and China-side effects; designed with counsel in both countries.
DeliverableStructure comparison memorandum
05
Maintenance
How does the structure stay compliant?
Facts to establishForms 3520 / 3520-A, 5471, 8621, 8938 and FBAR; distribution planning; a contingency plan for the grantor's death.
DeliverableAnnual compliance calendar
02Key Considerations
Key Considerations
Estate Exposure
The older generation's U.S. assets
U.S. real estate, stocks and company shares held by nonresidents are U.S.-situs with a $60,000 exemption; direct, corporate and trust ownership each trade estate tax against basis and carrying cost.
Foreign Trusts
Different rules before and after death
During the grantor's life, distributions to U.S. beneficiaries are generally untaxed; afterwards the trust usually becomes non-grantor and accumulated income is taxed with an interest charge when distributed.
CFC & PFIC
Foreign companies and Chinese wealth products
U.S. shareholders may be taxed annually on certain CFC income; Chinese funds, wealth products and some policies are often PFICs, costly without annual statements.
Gifts & Reporting
The gift is untaxed; missed reporting is penalized
Gifts from nonresidents over $100,000 a year require Form 3520, with penalties up to 25%; gifts of U.S. real estate are subject to gift tax, gifts of U.S. stock generally are not.
California
Two California rules
Community property with right of survivorship can adjust the basis of the whole asset at the first death, joint tenancy usually half; Prop 19 limits parent-child property tax transfers.
03Illustrative Analysis
$5 million of U.S. assets, three arrangements
Parents are Chinese tax residents and U.S. nonresidents directly holding a $3,000,000 California rental and $2,000,000 of U.S. stocks; their child is a U.S. citizen. Federal estate and gift tax only.
| A · As is | B · Lifetime gift of stocks | C · Foreign holding company | |
|---|---|---|---|
| U.S.-situs assets at death | $5,000,000 | $3,000,000 | Generally none (foreign shares) |
| Federal estate tax (approx.) | ≈ $1,933,000 | ≈ $1,133,000 | Generally not applicable |
| Child's basis | Adjusted at death | Stocks carry over; real estate adjusted at death | No adjustment |
| Other costs | — | Form 3520 in the gift year | Ongoing tax, FIRPTA and reporting; transfer consequences assessed first |
Reading the Analysis
Option B reduces estate exposure by about $800,000 at the cost of the basis adjustment on those stocks, which may exceed the tax saved where gains are large. Option C removes estate tax but adds ongoing tax and reporting. The choice depends on gains, holding period, the parents' ages and family plans.
Illustrative only; not a specific client. Estate tax estimated on the 2026 rate table with the $13,000 nonresident credit; excludes China-side tax, state tax and costs. No outcome is promised.
04Perspective
Professional Background
Planning is tested years later — in an audit, a diligence process or a family event. Every document is prepared to that standard.
CFA®Investment analysis
Earned in securities and investment firms; for Chinese funds, wealth products and policies, the underlying assets, issuer and available information are established first.
CPALicense & signature
A U.S. CPA license: opinions are signed, and models are reviewable and traceable.
EAIRS representation
Authorized to represent taxpayers before the IRS; when cross-border reporting is questioned, the firm responds directly.
J.D.Legal process (candidate)
Pursued after a first-hand U.S. legal proceeding; cross-border succession rests on powers of attorney, notarizations, trust terms and heirship declarations, handled with counsel at the clause level.
The firm sells no insurance or investment products and charges no asset-based fees.
05Engagement
Terms of Engagement
Initial consultations are arranged by email and a review of basic information.
01
First session
$599
30 minutes with Wen Shi, in person in Irvine if preferred, followed by a one-page memorandum of U.S. exposure, open windows and next steps.
Credited in full upon engagement
Email us firstAlready in touch? Book · $59902
Event planning
Scoped quote
Pre-immigration planning, the older generation's U.S. assets, foreign trust and company review, remediation of prior filings — options compared and executed with counsel in both countries.
Scope and fee agreed in writing
03
Annual advisory
Annual retainer
Compliance calendar and filings, distribution planning, immediate involvement on changes, IRS representation.
For families with a structure in place
Initial Consultation
- 1
Email
A brief description of the matter. Email is used for initial correspondence only.
- 2
Information
Sensitive documents through an encrypted channel, under an NDA where appropriate.
- 3
Confirm & book
Once fit is confirmed, book and pay $599.
- 4
Session & memo
A 30-minute session, by video, phone or in person in Irvine, followed by a one-page written memorandum.
06Suitability
Typical Clients
- Families whose parents are Chinese tax residents holding U.S. real estate, stocks or company shares
- Families about to receive a green card or naturalize while holding assets in China
- Families with a foreign trust, existing or planned, with U.S. beneficiaries
- Families with unreported foreign gifts, accounts or companies in prior years
Outside Our Scope
- A routine annual return only
- Price as the primary criterion
- A guaranteed amount of tax savings
- Investment or insurance product recommendations
Where a consultation shows the matter is outside our scope, we say so and refund the fee.
Most arrangements have a deadline
Before residency, during the parents' lifetimes, before naturalization, while property remains in the parents' names — after these points, what remains is costlier remediation.
Email is for initial communication only. Sensitive documents are not sent by ordinary email; the channel is arranged separately, with an NDA where appropriate.
General tax information only; not tax, legal or investment advice for any specific situation. Rules and amounts may change and apply only on specific facts. Wen Shi is a Certified Public Accountant, an Enrolled Agent and a CFA® charterholder, and a J.D. candidate who does not provide legal advice. The firm gives no investment advice and sells no insurance or investment products. Trust drafting, immigration filings and probate are the practice of law.
Family Tax Advisory
Book
Family Tax Advisory · HNW Families · Cross-Border Assets · Succession
For cross-border families,sequence determines the outcome.
We advise families with assets in the United States and China on planning before a change in residency, the U.S. estate exposure of the older generation, the U.S. classification of foreign trusts and companies, and succession — implemented with counsel in both jurisdictions.
By email inquiry first · 30 minutes · in person in Irvine available · credited upon engagement Email is for initial communication only. Sensitive documents are not sent by ordinary email; the channel is arranged separately, with an NDA where appropriate.
Our View
Cross-border outcomes turn on sequence: residency before or after dispositions, a trust before or after gifts, arrangements made during the parents' lifetimes or after. The same assets in a different order can differ by millions, and most sequences cannot be reversed.
$60,000Estate tax exemption for U.S.-situs assets of nonresidents ($15,000,000 for citizens and residents)
40%Top federal estate tax rate above it; no U.S.–China estate tax treaty
75 daysFor a retroactive entity election after the grantor's death
5 yearsTrusts funded within five years before immigration may become grantor trusts (§679)
Three moments that decide the outcome.
Five points where the rules change
- U.S. tax residency beginsBasis of foreign assets can still be reset before the start date
- Funding a foreign trustWith U.S. beneficiaries, classification governs every later year
- During the parents' lifetimesGrantor-trust distributions to U.S. beneficiaries are generally untaxed
- Death of the grantorRetroactive entity elections must be made within 75 days
- Return or expatriation§877A exit tax and the 40% tax on U.S. recipients
How We Work
Analytical Framework
Five questions, taken in order; each answer determines whether the next is necessary.
1StatusWho is each family member under U.S. law?
Facts to establishCitizenship, green card, substantial presence, residency start dates and expected changes — parents and children separately.
DeliverableResidency map
2 AssetsWhat is each asset under U.S. law?
Facts to establishBy location, holding form and character: U.S.-situs assets, foreign companies (CFC / PFIC), foreign trusts, Chinese wealth products and policies.
DeliverableFamily balance sheet
3 WindowsWhich steps must precede a given point?
Facts to establishBasis resets before residency, lifetime distributions and gifts, post-death election deadlines — ranked by irreversibility.
DeliverablePre-immigration memorandum
4 StructureWhich holding form works under both systems?
Facts to establishDirect, corporate or trust ownership compared on estate tax, basis, annual reporting and China-side effects; designed with counsel in both countries.
DeliverableStructure comparison memorandum
5 MaintenanceHow does the structure stay compliant?
Facts to establishForms 3520 / 3520-A, 5471, 8621, 8938 and FBAR; distribution planning; a contingency plan for the grantor's death.
DeliverableAnnual compliance calendar
Key Considerations
Key Considerations
Pre-Immigration
The lowest-cost point is before residency
Before U.S. residency begins, sales, restructurings or entity elections can reset basis to current value; after the start date the same steps are taxable.
Estate Exposure
The older generation's U.S. assets
U.S. real estate, stocks and company shares held by nonresidents are U.S.-situs with a $60,000 exemption; direct, corporate and trust ownership each trade estate tax against basis and carrying cost.
Foreign Trusts
Different rules before and after death
During the grantor's life, distributions to U.S. beneficiaries are generally untaxed; afterwards the trust usually becomes non-grantor and accumulated income is taxed with an interest charge when distributed.
CFC & PFIC
Foreign companies and Chinese wealth products
U.S. shareholders may be taxed annually on certain CFC income; Chinese funds, wealth products and some policies are often PFICs, costly without annual statements.
Gifts & Reporting
The gift is untaxed; missed reporting is penalized
Gifts from nonresidents over $100,000 a year require Form 3520, with penalties up to 25%; gifts of U.S. real estate are subject to gift tax, gifts of U.S. stock generally are not.
California
Two California rules
Community property with right of survivorship can adjust the basis of the whole asset at the first death, joint tenancy usually half; Prop 19 limits parent-child property tax transfers.
Illustrative Analysis
$5 million of U.S. assets, three arrangements
Parents are Chinese tax residents and U.S. nonresidents directly holding a $3,000,000 California rental and $2,000,000 of U.S. stocks; their child is a U.S. citizen. Federal estate and gift tax only.
A · As isB · Lifetime gift of stocksC · Foreign holding company
U.S.-situs assets at death
$5,000,000$3,000,000Generally none (foreign shares)Federal estate tax (approx.)
≈ $1,933,000≈ $1,133,000Generally not applicableChild's basis
Adjusted at deathStocks carry over; real estate adjusted at deathNo adjustmentOther costs
—Form 3520 in the gift yearOngoing tax, FIRPTA and reporting; transfer consequences assessed firstHow to read it
Option B reduces estate exposure by about $800,000 at the cost of the basis adjustment on those stocks, which may exceed the tax saved where gains are large. Option C removes estate tax but adds ongoing tax and reporting. The choice depends on gains, holding period, the parents' ages and family plans.
Illustrative only; not a specific client. Estate tax estimated on the 2026 rate table with the $13,000 nonresident credit; excludes China-side tax, state tax and costs. No outcome is promised.
Perspective
Planning is tested years later — in an audit, a diligence process or a family event. Every document is prepared to that standard.
Wen Shi · CPA, EA, CFA®
CFA®Investment analysis
Earned in securities and investment firms; for Chinese funds, wealth products and policies, the underlying assets, issuer and available information are established first.
CPALicense & signature
A U.S. CPA license: opinions are signed, and models are reviewable and traceable.
EAIRS representation
Authorized to represent taxpayers before the IRS; when cross-border reporting is questioned, the firm responds directly.
J.D.Legal process (candidate)
Pursued after a first-hand U.S. legal proceeding; cross-border succession rests on powers of attorney, notarizations, trust terms and heirship declarations, handled with counsel at the clause level.
The firm sells no insurance or investment products and charges no asset-based fees.
Engagement
Terms of Engagement
First session
$599
30 minutes with Wen Shi, in person in Irvine if preferred, followed by a one-page memorandum of U.S. exposure, open windows and next steps.
Credited in full upon engagement
Email us first Already in touch? Book · $599Event planningScoped quote
Pre-immigration planning, the older generation's U.S. assets, foreign trust and company review, remediation of prior filings — options compared and executed with counsel in both countries.
Scope and fee agreed in writing
Annual advisoryAnnual retainer
Compliance calendar and filings, distribution planning, immediate involvement on changes, IRS representation.
For families with a structure in place
How it works
- EmailA brief description of the matter. Email is used for initial correspondence only.
- InformationSensitive documents through an encrypted channel, under an NDA where appropriate.
- Confirm & bookOnce fit is confirmed, book and pay $599.
- Session & memoA 30-minute session, by video, phone or in person in Irvine, followed by a one-page written memorandum.
Suitability
Typical Clients
- Families whose parents are Chinese tax residents holding U.S. real estate, stocks or company shares
- Families about to receive a green card or naturalize while holding assets in China
- Families with a foreign trust, existing or planned, with U.S. beneficiaries
- Families with unreported foreign gifts, accounts or companies in prior years
Outside Our Scope
- A routine annual return only
- Price as the primary criterion
- A guaranteed amount of tax savings
- Investment or insurance product recommendations
Where a consultation shows the matter is outside our scope, we say so and refund the fee.
Most arrangements have a deadline
Before residency, during the parents' lifetimes, before naturalization, while property remains in the parents' names — after these points, what remains is costlier remediation.
Email us first Already in touch? Book · $599General tax information only; not tax, legal or investment advice for any specific situation. Rules and amounts may change and apply only on specific facts. Wen Shi is a Certified Public Accountant, an Enrolled Agent and a CFA® charterholder, and a J.D. candidate who does not provide legal advice. The firm gives no investment advice and sells no insurance or investment products. Trust drafting, immigration filings and probate are the practice of law.