Entry / Exit Tax Planning

Moving into or out of the U.S. or Korea triggers some of the most complex tax rules in both countries.

Residency can change mid‑year, income sourcing rules shift, and both governments may claim taxing rights depending on:

• Visa or immigration status
• Days of presence
• Family and economic ties
• Asset location
• Timing of entry or departure

Entry / Exit Tax Planning ensures that your move is structured to minimize tax, avoid double taxation, and stay fully compliant with both U.S. and Korean rules.

Clients often ask:

• “When do I become a U.S. tax resident — and when do I stop being one”
• “If I leave the U.S., do I still owe tax on worldwide income”
• “How do I report income earned before or after moving”
• “Do I need to file a dual‑status return”
• “What happens to my Korean accounts when I become a U.S. resident”
• “Do I owe exit tax when giving up a green card”
• “How do I avoid double taxation during the year I move”

These questions are extremely common — and the timing of your move can dramatically change your tax outcome.

We help you plan your move strategically so you avoid unnecessary tax and reporting burdens.

✔ Determine Residency Status (U.S. & Korea)

• Substantial Presence Test
• Green card residency
• Dual‑status year analysis
• Korean residency rules (domicile, family ties, economic ties)
• Treaty tie‑breaker rules

✔ Plan for Entry Into the U.S. or Korea

• Residency start date optimization
• Pre‑immigration tax planning
• Asset restructuring before becoming a U.S. resident
• PFIC/CFC risk mitigation
• Foreign account reporting preparation (FBAR, FATCA)

✔ Plan for Exit From the U.S. or Korea

• Residency termination date
• Dual‑status return filing
• Final-year foreign tax credit coordination
• Korean departure tax considerations
• U.S. expatriation rules (Form 8854) for long‑term green card holders

✔ Avoid Double Taxation During the Move Year

• Split‑year income allocation
• Sourcing rules for salary, bonus, RSUs
• Rental income and capital gains timing
• Treaty application for cross‑border income

✔ Optimize Asset Location Before and After the Move

• U.S. vs Korean brokerage accounts
• Real estate ownership
• Pension and retirement accounts
• Business ownership restructuring
• Gifting or trust planning before relocation

Entry and exit planning must be precise, coordinated, and forward‑looking.

• Treaty‑aligned: We apply the U.S.–Korea tax treaty strategically
• Holistic: Residency, income, assets, and reporting all work together
• Timing‑focused: The date of your move can change everything
• Risk‑controlled: Avoid PFIC, CFC, and expatriation tax traps
• Clear explanations: No jargon — you understand your plan