The US has been and continues to be a desirable place for high net worth foreign individuals to move to. Timely pre-immigration US tax planning is critical for a high net worth foreigner who is considering moving to the US, and the failure to plan until it is too late may have extremely costly US tax consequences.
Take, for example, the case of a successful individual who is not a US citizen or resident and who lives in a foreign country. This individual has significant wealth of her own. She owns foreign companies that she founded years ago and that are now extremely valuable, and she has also invested in a portfolio of stocks that has appreciated significantly. In addition, this individual stands to inherit significant wealth from her parents, who are also not US citizens or residents.
This individual is considering moving to the US with her spouse and children, while her parents will remain abroad. This move will bring with it a host of potential US tax liabilities. With proper planning, however, this individual can take legitimate steps in advance to significantly minimize US taxes once she becomes a US citizen or tax resident.