FreemanBarraza

A specialist practice

Global in reach. Personal by design.

Who we serve internationally

  • US families with accounts, businesses, trusts, or property abroad
  • Business owners with operations in more than one country
  • Foreign investors in US real estate and US businesses
  • Multigenerational families planning succession across borders
  • Non-US origin families who invest, live, or have other ties to the US
  • Executives and professionals with international compensation, or moving to or from the US

Most firms treat international tax as an add-on: someone files the FBAR and moves on, while a different advisor in each country works without ever speaking to the others. We built the opposite. Families and business owners whose lives cross borders get one partner who sees every jurisdiction at once, and a written strategy that will assist in coordinating all of them.

Our international practice is led by Fernando Barraza, CPA, MAcc, who grew up on the US-Mexico border and has dedicated his career to cross-border tax strategy for high and ultra-high-net-worth families and businesses. He advises in English and Spanish, coordinates directly with attorneys and accountants in each country, and lives the same cross-border life his clients do.

Meet Fernando Barraza →

International Services

From formation to exit, and beyond.

International Tax Compliance

If you are a US person (citizen, green card holder, or resident under substantial presence), your worldwide assets carry US reporting obligations, no matter where they sit. Foreign banks already report US account holders to the IRS automatically under FATCA. The question is whether your filings match what the IRS already knows.

Who this is for: US persons with foreign accounts, entities, trusts, or investments anywhere in the world, including those who only just discovered they were out of compliance.

Ask About Your Compliance Position
  • FBAR (FinCEN Form 114) preparation and filing for foreign financial accounts
  • FATCA reporting: Form 8938, Statement of Specified Foreign Financial Assets
  • Foreign trust reporting: Forms 3520 and 3520-A
  • PFIC analysis and elections for foreign mutual funds and investment vehicles (Form 8621)
  • Foreign corporations and partnerships: Forms 5471, 5472, 8865, 1120-F, 8858
  • GILTI and NCTI inclusions for US shareholders of foreign corporations
  • Delinquent filing remediation, streamlined procedures, and voluntary disclosure

Cross-Border Tax Strategy

Tax systems do not naturally align across borders. Without intentional coordination, families and businesses end up with phantom income, double taxation on the same dividend, missed treaty benefits, or structures that trigger tax in one country to save it in another. Strategy means building the structure once, correctly, across every jurisdiction at the same time.

Who this is for: business owners with operations in more than one country, and families whose holdings span jurisdictions.

Discuss Your Structure
  • Entity structuring and restructuring across jurisdictions
  • Tax treaty analysis and optimization, US-Mexico and worldwide
  • Cash repatriation and cross-border dividend strategy
  • Pre-transaction tax modeling, so you know the tax cost before the deal closes
  • Foreign tax credit planning and double-taxation relief
  • Coordination with your attorneys, wealth managers, and foreign accountants
  • In-depth inbound and outbound international tax strategies

Cross-Border Real Estate With our Real Estate Practice

This is where our real estate and international practices meet. Foreign investors buying US property face FIRPTA withholding, US estate tax exposure, and entity choices that look very different from the US-owner playbook. US owners of property in Mexico or elsewhere face reporting, fideicomiso, and inheritance questions most real estate CPAs never see. We structure the acquisition, operation, and exit in both tax systems from day one.

See the Real Estate Practice
  • Inbound investment structuring for foreign buyers of US real estate
  • FIRPTA planning, withholding certificates, and exit strategy
  • US estate tax exposure for non-resident owners of US property
  • US owners of foreign property: reporting, fideicomisos, and rental income
  • Partnership and LLC structures with foreign partners (withholding and reporting)

Estate & Generational Wealth Planning

A cross-border estate is dramatically more complex than a domestic one. It must address how assets are titled in each country, which country's law governs each asset class, how the US estate tax interacts with foreign inheritance rules, and whether your trust structure will even be recognized across jurisdictions. Most families discover the gaps only after the patriarch or matriarch passes, when the options are narrowest and the costs are highest.

Who this is for: families with significant assets, heirs, properties, or businesses in more than one country, especially those without a coordinated written plan.

Start the Estate Conversation
  • Coordinated cross-border estate plan design with counsel in each country
  • Trust structures that function across jurisdictions
  • Family business and real estate portfolio succession planning
  • US estate and gift tax mitigation for multinational families
  • Pre-immigration and expatriation tax planning
  • Generational wealth transfer strategy

M&A & Transaction Advisory

The most expensive tax problems are created at the deal table: an overlooked provision, an unmodeled gain, a structure that made sense in one jurisdiction and detonated in another. We sit on your side of the transaction and model the tax implications before you sign, not after.

Who this is for: owners buying, selling, restructuring, or expanding a business, especially across a border.

Talk Before You Sign
  • M&A due diligence: tax exposure and compliance review of the target
  • Business valuation coordination
  • Restructuring of entities, holding companies, and cross-border groups
  • International expansion strategy for entering the US or foreign markets
  • Deal structuring and pre-closing tax modeling

One firm. Every border.

Deepest specialization in US-Mexico cross-border planning, with a career spent advising families and businesses connected to jurisdictions across the globe.

  • United States
  • México
  • Canada
  • Central America
  • South America
  • Europe
  • Asia
  • Australia

Ready when you are

The three most expensive words in international tax: "we'll deal with it later."

Thirty minutes, in English or Spanish. A diagnostic, not a sales call.

Schedule a Consultation →