Research & publications
Practical perspectives on U.S. trade, tax and cross-border planning.
Articles
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U.S. Assets, Non-U.S. Families: Begin With Status and Ownership
Income-tax residency and estate-tax domicile are different questions. Cross-border planning starts by mapping each family member’s status and exactly how each U.S. asset is owned.
Cynthia Wu · 6 min read -
IEEPA Tariff Refunds: Begin With the Entry Record
The importer of record, each entry’s liquidation history and any prior filings set the starting point for a tariff refund review — not a headline about a court ruling.
Cynthia Wu · 2 min read -
When CBP Holds Your Shipment: What to Gather First
Start with the written notice, the entry documents and a clear timeline. An examination, a detention and a seizure are different procedures, and the response depends on which one you are facing.
Cynthia Wu · 6 min read -
Implementing IEEPA Tariff Refunds After Learning Resources: The CIT’s Refund Orders, Administrative Feasibility, and the Unresolved “Final Liquidation” Gap
Update (November 2026). This article reflects developments through late May 2026. Since then, CBP has expanded the process: it IEEPA refunds through CAPE (Consolidated Administration and Processing of Entries)…
Cynthia Wu · 24 min read -
IEEPA Tariff Refunds After Learning Resources v. Trump: Legal Bases, Procedures, and Practical Strategy
Update (November 2026). CBP now processes IEEPA refunds through CAPE (Consolidated Administration and Processing of Entries) in ACE.
Cynthia Wu · 23 min read -
Estate Planning for Nonresident Aliens Who Own U.S. Real Estate: Federal Tax Issues
Website edition, corrected November 2026: several illustrative figures in the tax computations have been updated. by: Cynthia Wu on Jan 24, 2026Navigating the federal tax implications for nonresident aliens…
Cynthia Wu · 22 min read -
Understanding Reverse 1031 Exchanges and the Risks of International Fund Transfers
Understanding Reverse 1031 Exchanges and the Risks of International Fund TransfersAt our law firm, we are helping clients navigate complex tax strategies, including 1031 exchanges, which allow taxpayers to…
Cynthia Wu · 6 min read -
NRA Grantor Trusts with U.S. Beneficiaries: Comparing Domestic and Foreign Structures
IntroductionNonresident aliens (NRAs) who wish to establish trusts for the benefit of U.S. beneficiaries often face complex U.S. tax considerations.
Cynthia Wu · 6 min read -
Understanding the Grantor Trust Rules Under IRC § 679: Key Considerations for Foreign Trusts
When it comes to estate planning and asset protection, foreign grantor trusts can be a powerful tool. However, navigating the complex U.S.
Cynthia Wu · 6 min read -
Foreign Grantor Trusts: How Grantors and U.S. Beneficiaries Are Taxed
When a foreign trust is a grantor trust, who pays the tax, how distributions to U.S. children are treated, what changes when the grantor dies, and which forms U.S. beneficiaries must file.
Cynthia Wu · 6 min read
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