Luis Dena Osollo
Attorney at Law (California) / Solicitor of England & Wales
Questions relating taxation with respect to business planning (and personal estate planning) are particularly complex when more than one country is involved. Simple contexts in which such questions arise are when: (1) a citizen or resident of country A owns assets in country B; (2) a citizen of country A works (and lives) in country B; (3) a citizen of country A is married to a citizen of B; (4) citizen of country A lives in country B, owns assets in country C, and dies while in country D, and so forth.
The U.S. has a broad jurisdictional base for business and estate and gift taxation, taxing its citizens and permanent residents regardless of their domicile or the location of their assets. Incidents of double (and triple) taxation are increasingly common (without proper planning). Obversely, a foreign person that wishes to move to the US must be careful to consult with a qualified legal professional to discuss pre-immigration tax planning issues so as not to transfer certain assets that generate royalties to the US to avoid its worldwide tax net.
This is why it is critically important to consult with a qualified local legal professional to resolve the many complex issues in this area if you are considering expanding your business (and it's personnel) beyond the borders of the US, or are interested in establishing a foreign branch, subsidiary, or permanent establishment within the borders of the US from abroad.
If you and your business are considering such an expansion, let's discuss what inernational business and tax planning options are available given your specific plans and the target national market(s) that you wish to enter. Tax planning issues are critically important to be addressed before committing your time and money.
My initial fifteen minute consultation with you is always free.
- Tax Law
- Business Taxes, Estate Tax Planning, International Taxes, Tax Planning
- Estate Planning
- Health Care Directives, Trusts, Wills
- International Law
- Imports & Exports
- Business Law
- Business Contracts, Business Formation, Mergers & Acquisitions, Partnership & Shareholder Disputes
- Antitrust Law
- Int'l Bus. & Tax Planning of Foreign Bus. Ops. in the US
- California
- State Bar of California
- Solicitor of the Senior Courts of England and Wales
- United States Court of International Trade (New York)
- United States District Court, Northern District of California
- United States Tax Court (District of Columbia)
- California St Univ
- B.A. | English
- Santa Clara University School of Law
- Law Degree
- Honors: Law Faculty Research Assistant to Philip J. Jiménez, Professor of Law
- Golden Gate University School of Law
- LL.M. | Taxation (International Tax Planning Issues & Controversies Respecting Foreign Source Income of US Citizens, Resident Aliens, & US Bus. Operations Abroad; Estate Planning & Tax'n; Int'l Estate Planning for US Taxpayers, Pre- US Immigration Tax Planning)
- The Hague Academy of International Law
- Private International Law (Certificate)
- 2517 KJ The Hague, Peace Palace, The Netherlands
- Honors: Charles A. Dana Foundation Scholarship Recipient
- California State Bar
- Member
- Current
- Law Society of England & Wales, London, United Kingdom
- SRA-Regulated Solicitor
- Current
- United States Court of International Trade
- Member of the Bar of the United States Court of International Trade
- Current
- American Bar Association
- Member
- - Current
- "California's 'Unitary Method' of Allocating Jurisdiction to Tax Income from Multi-State (or Nation) Business: International Application and Implications"
- 6 Tilburg L. Rev. 289-367, Tilburg University, The Netherlands