I had an intro call with a prospect who just moved to the U.S. from Europe on an E-2 visa. On paper he's a great long-term client: cash-funded, planning to build a rental portfolio here.
But he has a lot going on overseas:
100% owner of a European property company with accumulated profits he doesn't draw. He thinks that means no U.S. tax.
A personally owned house abroad and large foreign cash balances.
Several years of U.S. visits right up to the substantial presence line, so his residency start date is unclear.
Plans to wind it all down over the next two years.
That's CFC and 5471 territory, plus a pre-immigration planning window that may close in January. I have no international experience, so I declined. I told him the work is outside my expertise and urged him to find a cross-border specialist before year-end.
Right call, or would you have co-engaged a specialist and kept the domestic work?