Services

The impact of wealth management on clients:
- No change to the capital gains tax (Capital Gain)
- Retention of the Net Investment Income Tax (Net Investment Income Tax)


Impacts on estate/gift taxation and trust planning:
- Doubling of the lifetime exemption amount; adjusted upward to USD 13,990,000 in 2025
- Retention of the stepped-up basis
- Individual income tax reform may affect trust income tax returns (e.g., reduced individual tax rates, limitations on itemized deductions, etc.)
- For pass-through entities, individual shareholders are granted an additional 20% deduction, but this deduction is also subject to other limitations/requirements
- The lifetime exemption is subject to a sunset provision; planning should take advantage of this window
- Trust planning: Gift Selection Factors
- If future U.S. immigration and obtaining U.S. citizenship is contemplated, adjustments for future wealth succession based on Taiwan domestic investments may allow greater flexibility. Consider, prior to immigration, adopting compliant “foreign-investment structuring” approaches to reduce potential tax costs in Taiwan.


Common U.S. family wealth planning tools:

U.S. tax information is complex, and different situations require different forms to be completed; even the required entries on those forms may vary.


Joy Yang has extensive experience handling complex cases for a wide range of clients, for example, when a family leaves U.S.-situs assets (e.g., U.S. stocks held through a discretionary/managed account, or directly held U.S. equities). We advise on how to properly claim the inheritance and file compliant tax returns. In such cases, Form 706 or Form 706-NA must be filed, and there are strict filing deadlines.


Another common example is pre-immigration tax planning. Many individuals worry about double taxation after immigrating, so advance asset allocation and planning are needed. Tax planning before children go to the U.S. for education is also a frequently consulted topic. In recent years, Zhuoyue has assisted many clients in establishing tax plans tailored to each client’s circumstances.

Common tax benefits include the Standard Deduction. In 2025, the standard deduction increased to USD 15,000 and is adjusted annually based on the Consumer Price Index (CPI).






Most Taiwan–U.S. dual-national clients can claim the Foreign Tax Credit. If taxes are paid overseas, the tax paid to the source country may be used as a credit against U.S. tax. Note that the same item of foreign income cannot be used for both the Foreign Tax Credit and the Foreign Earned Income Exclusion.


The Child Tax Credit is a partially refundable credit that allows low- and middle-income families to reduce their tax liability by up to USD 2,000 per qualifying child.


The Earned Income Tax Credit (EITC) introduced certain new rules for taxpayers affected by the pandemic in 2021. In addition, EITC eligibility requirements vary from year to year. Taxpayers can use the IRS EITC Assistant to determine whether they qualify. Note that taxpayers filing “married filing separately” are not eligible to claim the EITC.


With many years of filing experience, Joy Yang has assisted numerous clients with tax filings and, based on each client’s circumstances, applied different deduction and credit strategies to help clients reduce their tax burden effectively.

Joy Yang has found that most U.S. tax residents living in Taiwan are familiar with filing individual income tax returns (Form 1040), but many overlook FBAR and FATCA reporting.


These two filings must not be missed. Intentional non-filing may result in civil and criminal liability.


The chart below helps explain the differences between FBAR and FATCA.
 




Feature
FBAR(FinCEN 114)
FATCA(Form 8938)


Supervising authority
Financial Crimes Enforcement Network (FinCEN)
Internal Revenue Service (IRS)


Types of accounts/assets reported
Foreign bank accounts, deposit accounts, investment accounts, trust accounts, etc.
_


Filing threshold
At any time during the year, the aggregate value of foreign accounts exceeds USD 10,000
USD 50,000 for single or married filing separately; USD 100,000 for married filing jointly


Filing deadline
By April 15 each year; typically can be extended to October 15
_


Scope of reporting
Applies only to foreign financial accounts; does not include other foreign assets
_


Details required
Basic information for each foreign account, e.g., account number, financial institution name, maximum balance, etc.
Basic information for each specified foreign financial asset, e.g., asset type, account/asset value, etc.





 

The U.S. requires worldwide asset/income reporting, so dual nationals who are U.S. tax residents often need to file multiple types of forms (e.g., Forms 1040, 1099, 8938). In particular, for those with Taiwan-sourced salary income, it is common to be unsure where and how to report items such as labor and health insurance contributions under Taiwan’s system in a compliant manner.


Failure to meet U.S. filing obligations, or filing incorrectly, may result in higher tax liabilities and/or late-filing penalties.


With years of experience, Joy Yang assists clients in preparing and filing a wide range of U.S. tax forms. Unlike many peers, Joy Yang insists that each client’s tax return is prepared and completed directly by a U.S. CPA. To help avoid double taxation between Taiwan and the U.S. Joy Yang also reviews each client’s circumstances to identify applicable credits and is pleased to have helped many clients reduce their overall tax burden.


Joy Yang also serves clients who, due to personal needs, must file delinquent returns for the past seven years. U.S. tax residents who have not met their filing obligations for many years are not uncommon. Joy Yang provides back-filing services and prepares an individualized Streamlined submission (Streamlined Filing Compliance Procedures) for submission to the U.S. federal government to explain the reasons for prior noncompliance—fully supporting clients’ needs and aiming to achieve the lowest possible tax cost.

In today’s globalized business environment, both companies and individuals often feel significant pressure from tax laws and compliance requirements when facing audits by the U.S. Internal Revenue Service (IRS). To help clients navigate these challenges smoothly, we provide professional tax compliance and IRS audit support services.


Joy Yang's professional team has extensive knowledge of U.S. tax law and can assist clients in understanding and complying with U.S. tax regulations. We also provide strategic advice to ensure all filing requirements are fully met. Whether handling tax audits, responding to IRS inquiries, or preparing the necessary documentation, we deliver end-to-end support to safeguard clients’ legal rights and interests. Through professional planning and response strategies, we help clients reduce potential penalties and tax risks, and effectively resolve a wide range of tax disputes, so clients can focus confidently on developing their core business.

In the M&A process, tax planning plays a critical role. U.S. tax support has far-reaching implications for transaction structuring, asset dispositions, and post-merger operations.






When conducting an acquisition or merger, companies must evaluate a wide range of tax implications, including (but not limited to) capital gains tax, income tax, sales tax, and tax issues arising from interstate and cross-border transactions. First, the company must determine the form of the transaction. Common structures include asset purchases and stock purchases. Asset purchases often provide greater tax benefits to the buyer, for example, allowing depreciation or amortization based on the newly acquired assets, thereby reducing future tax burdens. In a stock purchase, however, the buyer typically cannot access these tax benefits immediately, but may avoid the administrative complexity associated with asset transfers. Second, the financing structure of the transaction also affects tax outcomes. For instance, if a company chooses to finance the acquisition, it must assess whether interest expense is tax-deductible and whether this could increase the overall tax burden. Cash consideration, by contrast, avoids interest costs associated with borrowing, but may place pressure on the buyer’s cash flow.

In addition, the transaction structure must take into account potential tax benefits or preferential policies. Under certain conditions in U.S. tax law, corporate reorganizations may qualify for tax advantages (for example, under Section 338 or Section 368). These provisions can reduce the post-merger tax burden and make the acquisition process more efficient.

A corporate holding structure should be designed with both tax and non-tax considerations in mind. A brief overview is provided below.


Tax considerations: 
1. Dividend distributions
2. Accumulated Earnings Tax (AET)
3. Effectively Connected Income (ECI)
4. Foreign Tax Credit (FTC)
5. Capital gains (exit strategy)
6. Controlled Foreign Corporation (CFC)
7. Place of Effective Management (PEM)


Non-tax considerations: 
1. Future M&A transactions
2. Future exit strategy
3. Capital structure
4. Financing and funding arrangements
5. Related legal procedures
6. Future IPO considerations

In addition, from a tax perspective, under IRS regulations, qualifying taxpayers are required to file Form 5471, which is intended to disclose a U.S. tax resident’s ownership interests in foreign corporations and to prevent tax residents from using offshore companies to engage in tax avoidance.

Many Taiwanese companies and individuals engaged in cross-border operations face the challenge of U.S. double taxation. To effectively reduce the overall tax burden between the United States and Taiwan, we provide professional double-tax planning services. We help clients design optimal tax structures across the U.S. and Taiwan to maximize tax efficiency and reduce tax risks.






Our professional team assists both businesses and individuals in understanding U.S. tax rules, such as estate tax, income tax, and the Foreign Tax Credit (FTC), and provides tailored solutions, including selecting appropriate entity structures and leveraging available exemptions and relief provisions. Through precise tax planning and lawful tax mitigation strategies, we help clients reduce tax costs and ensure U.S. tax compliance for both companies and individuals.

Form 8854 (Initial and Annual Expatriation Statement) applies to U.S. citizens who renounce their citizenship and long-term residents (foreign nationals) who terminate their U.S. lawful permanent resident status.


A Covered Expatriate may be subject to the expatriation tax, under which the individual is treated as having sold all worldwide assets at fair market value on the day before expatriation. The difference between fair market value and the original cost basis is calculated as unrealized gain, and this gain is included in the individual’s taxable income for that year.


In addition, the individual must complete Form DS-4079 and schedule an appointment with the American Institute in Taiwan (AIT) for an in-person interview.

U.S. state sales tax consulting may include the following:


- Tax registration: Businesses selling products or providing services in the U.S. may need to complete the applicable tax registration procedures to obtain a sales tax permit/ID.

- Tax collection: Sales tax rates and collection rules vary by state and locality, so it is necessary to understand local tax regulations and filing procedures.

- Tax reporting and payment: Businesses must regularly file sales tax returns and remit the collected sales tax to the relevant tax authorities.
 


Tax considerations for business location selection:


- Corporate income tax rates and policies: Corporate income tax rates and policies differ across states and cities; companies should consider choosing the most favorable tax environment.

- Property tax and local taxes: Property tax and other local tax rates vary by jurisdiction, requiring a review of local tax conditions.

- Employment/payroll-related taxes: Some states and cities impose employment-related taxes; companies should consider headcount, total payroll, and the associated tax costs.

- Tax incentives: Understand local incentive programs—such as corporate tax credits and investment incentives—to minimize overall tax costs to the greatest extent possible.
 


Key tax issues for employees assigned to the U.S. :


- Tax residency: Assignees must determine their U.S. tax residency status to understand their federal and state tax filing and payment obligations.

- Tax treaties: Assignees should confirm whether the U.S. has a tax treaty with their home country to help mitigate double taxation.

- Social Security and Medicare taxes: Assignees may be subject to Social Security and Medicare taxes and should understand the related withholding, filing, and reimbursement procedures (as applicable).

- Credits and exemptions: Assignees may be eligible for certain federal and state credits and exemptions; it is important to understand the relevant rules and procedures.

Since President Trump took office in 2017, the United States has continued to apply stricter scrutiny to cross-border investments, with the aim of preventing certain taxpayers from using investments to avoid U.S. taxes. Form 5471 is primarily used to disclose a U.S. tax resident’s ownership interests in foreign corporations, helping prevent tax residents from using offshore companies for tax avoidance. Joy Yang has assisted clients with filing Form 5471 on multiple occasions.


In addition, we have helped many clients develop restructuring plans tailored to their specific circumstances and the jurisdiction of incorporation. For example, we assist clients in making entity classification and tax structure changes, such as converting an LLC’s tax treatment to a C corporation to access potential corporate tax benefits. We also support business owners through corporate transitions by coordinating and collaborating with their company accountants and legal counsel.