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Tax and Immigration Planning Part 2 “Understanding U.S. Immigration and Tax Residency”

In Part Two, Greenspoon Marder attorneys Hector Chichoni and Ruben Gotlieb dive deeper into the complex concepts of U.S. tax residency, domicile, and how intent can trigger significant income, gift, and estate tax consequences. With an eye toward planning for 2026 and beyond, they break down the mechanics of the substantial presence test, explain how day‑counting really works, and outline the limited exceptions available through tax treaties and the IRS “closer connection” framework. The conversation reinforces why income tax residency and estate and gift tax domicile are governed by entirely different legal standards and why confusing the two can be costly.

The episode also explores how immigration milestones such as filing an I‑140, adjustment of status, or entering the U.S. on a green card can have immediate and sometimes retroactive tax effects. Through real‑world examples, Hector and Ruben highlight how intent, asset location, family ties, and even timing of entry can shift an individual from pre‑immigration tax planning to full U.S. global taxation. Whether you are pursuing permanent residency, advising international clients, or structuring cross‑border assets, Part Two underscores a critical message: immigration strategy and tax planning must be coordinated from the outset to avoid unintended exposure and preserve long‑term flexibility.

If you have any questions or would like to connect with our speakers, please feel free to reach out to Hector and Ruben directly at the following:

[email protected] or call (305) 789-2744

[email protected] or call (305) 789-2785

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Featured Speaker:

  • Hector Chichoni, Partner, Immigration & Naturalization Practice Group, Greenspoon Marder
  • Ruben Gotlieb, Partner, International Wealth and Asset Planning and Wills, Trusts & Estates practice groups, Greenspoon Marder

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Learn more about Hector Chichoni and the Immigration & Naturalization Practice group at:

Learn more about Ruben Gotlieb, International Wealth and Asset Planning, and Wills, Trusts & Estates Practice Group at: