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Ashley works with clients to bring strategy, structure, clarity and confidence to their global financial lives and keep it that way. In 2013, Ashley founded Arete Wealth Strategists, a fee-only financial planning and investment management firm for Australian/American expatriates.

Strategic Exits for High-Growth Australian Businesses: Navigating US/Australian Cross-Border Tax & Estate Planning

Explore tax and estate planning strategies for Australian business owners with US ties, focusing on optimizing exits and mitigating double taxation during liquidity events, mergers, or IPOs. Key topics include QSBS opportunities, estate tax mitigation, and post-exit wealth preservation.

In this webinar, Arete Wealth Strategists Australia Founder/Principal Ashley Murphy, CFP® GFP Fellow explored critical tax and estate planning considerations for Australian citizen business owners with US/Australian cross-border ties who are preparing for liquidity events, mergers, acquisitions, or IPOs.

Designed for entrepreneurs whose net worth may exceed US estate tax thresholds ($13.99M per individual in 2025), the webinar addressed strategies to optimize exits while mitigating exposure to double taxation, PFIC complexities, and wealth transfer inefficiencies.

Some of the relevant issues that were addressed include:

QSBS (Qualified Small Business Stock) Opportunities
- Eligibility criteria for Australian businesses with US subsidiaries or operations
- Maximizing $10M+ capital gains exclusions under IRC §1202
- Interaction with Australia’s CGT regime and double tax agreements
QBI Deductions & Pass-Through Entity Optimization
- Structuring US LLCs/partnerships vs. Australian family trusts for §199A benefits
- Impact of cross-border ownership on Qualified Business Income thresholds
Estate Tax Mitigation Strategies
- Navigating the $13.61M US estate tax exemption (IRC §2010) for non-domiciled Australians
- Irrevocable life insurance trusts (ILITs), GRATs, and CRTs in cross-border contexts
- Pitfalls of Australian testamentary trusts under US tax code
Exit Tax & Expatriation Planning
- IRC 877A implications for green card holders/long-term residents
- Pre-exit restructuring to avoid Covered Expatriate status
- Community property vs. common law title optimization (CA/NV/TX considerations)
Post-Exit Wealth Preservation
- State-specific residency planning (no-income-tax jurisdictions vs. California’s 13.3% rate)
- Cross-border philanthropic vehicles (DAFs, private foundations)