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Plan B and U.S. Tax: Notes from the Total Access Conference, Panama City

Writer: Auric Private Client Advisory LLC
Auric Private Client Advisory LLC
Sep 17
2 min read
Milan Solarz-Patel at the Schiff Sovereign Total Access Conference, Panama City, September 2026

From September 17 through 19, 2026, Milan Solarz-Patel, J.D., LL.M. (Taxation), attended the Total Access Conference hosted by Schiff Sovereign in Panama City, Panama, on behalf of Auric Private Client Advisory LLC. The program brought together members, advisors, and specialists for two days of presentations, panel discussions, and workshops centered on one subject: building a Plan B. A Plan B means a second residency, a second citizenship, and assets held outside one's home country.


Why Panama City

Panama City was a fitting venue. It is a major financial and logistics hub, it uses the U.S. dollar, and it offers one of the more attractive residency programs in Latin America. The setting illustrated the conference theme: strategic position and sound policy create options.


What the Program Covered

The sessions addressed the following:

  • Residency and citizenship options in Latin America, including Panama, Colombia, Argentina, Ecuador, and Paraguay

  • Citizenship-by-investment programs in Türkiye and the Caribbean

  • Real estate in high-potential markets

  • Special economic zones, such as the zone in Roatán, Honduras

  • Offshore banking

  • Tax structuring and real asset investing


The U.S. Side of a Plan B

Auric Private Client Advisory LLC focuses on U.S. cross-border tax compliance. Many attendees were U.S. citizens and residents, and for them every element of a Plan B has a counterpart on the U.S. return. The United States taxes its citizens on worldwide income wherever they live. A second residency or passport does not change that.

Plan B step

U.S. reporting to consider

Second residency or citizenship

Continued U.S. filing on worldwide income; if U.S. citizenship is later renounced, Form 8854 and a possible exit tax

Foreign bank or brokerage account

Foreign trust

Foreign LLC or corporation

Form 8858, 8865, or 5471, depending on classification

Foreign real estate

Rental income and gains on the return; entity reporting if the property is held through a company or trust


Penalties for missed information returns are substantial and can apply even when no tax is due.


The Takeaway

A Plan B is sound planning. It works best when the U.S. reporting is built into the structure from the start, rather than addressed after the fact.


A follow-up post will introduce the specialists and advisors whom Milan met in Panama City.

If you are a U.S. person considering a second residency, a second citizenship, or an offshore structure, contact Auric Private Client Advisory LLC to review the U.S. reporting before you commit: https://www.auricllc.com/contact

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