Bayview Tax· San Francisco
中文Correspondence →
A boutique international tax & consulting firmSan Francisco, California · Est. 2024

Your business is global.
Your tax position
deserves a firm that is, too.

For the founder-owner

Bayview is a boutique firm for the founder whose business and personal affairs cross borders. One partner, one engagement, every jurisdiction you touch — without the hand-offs of the Big-4 or the single-country blind spots of a local CPA.

Begin correspondence →Continue to the problem ↓Engagements by introduction · Confidentiality as default
Clients, typically

Founder-owners whose business is global.

Most of our clients share a handful of the same problems — and it is almost always the overlap that makes the situation hard. Five in particular:

  1. i.

    Multiple countries.

    Operating companies, holding vehicles, or bank accounts in two or more jurisdictions. Transfer-pricing exposure, permanent-establishment risk, treaty positions and withholding — touched by every new contract.

  2. ii.

    Multiple US states.

    Sales-and-use nexus after remote workforces, apportionment disputes, combined-reporting states, and the handful that tax foreign earnings on their own terms.

  3. iii.

    International tax complexity.

    GILTI, Subpart F, §962 elections, PFIC classification, CFC attribution, check-the-box planning, Forms 5471 / 5472 / 8865 / 8858. Mis-filed once, they follow you for years.

  4. iv.

    Family equity, reporting, and foreign holdings.

    Ownership scattered across operating co., holding co., trusts, and a fund interest — compounded by FBAR / FinCEN 114, Form 8938, and every international information return triggered when family members hold interests directly or by attribution.

  5. v.

    Foreign tax credit planning.

    §901 and §904 basketing, treaty tie-breakers, dual-residency splits, and credit carryovers across high-tax and low-tax jurisdictions — so foreign tax paid actually offsets US liability, rather than stranding in the wrong basket.

If two or three of these describe your file, the engagement is rarely about any one of them — it is about the shape they form together.

§ I

Does any of this sound familiar?

Six situations · paraphrased from real engagements
The one-country CPA

My US CPA is excellent — until anything touches China. Then it becomes a three-week email chain between four people.

Founder · 3 entities · 2 countries
The fifty-state surprise

We went remote, then distributed, then somehow nexus-ed into eleven states. I learned about the last three from certified mail.

CEO · Series B · distributed team
The “I just found out”

I did not know I was required to file a 5471. I also did not know what a 5471 was.

First-time founder · foreign subsidiary
The cap-table picture

Equity in the US co., equity in the HK co., profits interest in the fund — and no one has ever looked at the three of them as one picture.

Founder-operator · pre-series C
The quiet relocation

I moved in March. By October I realised my old planner had no idea what the new country does to a U.S.-grantor trust.

Family principal · relocated
Taxed twice, credited once

We paid tax in Germany and again in the US, and the foreign tax credit somehow ended up in a basket no one could fully explain to me.

Founder · US–EU dual entity

If two or more feel familiar — that is precisely why we exist.

§ II

Why the usual options don’t fit a global founder.

The landscape, honestly
Option ABig-4 firm
Option BLocal CPA
Option CDIY & software
BayviewBoutique, partner-led.
Who does the work
Partner signs; a junior runs it.
A generalist who sees you annually.
You do. Software ingests; you judge.
A named partner, from intake to filing.
Cross-border depth
Deep in each silo; slow between them.
One jurisdiction. A referral for the rest.
None. Tools stop at the US return.
40+ jurisdictions, one file, one voice.
How you’re billed
Hourly. Scope creep is the business model.
Annual fee, plus everything “complicated.”
A subscription. And your weekends.
Flat engagement letters. No surprises.
The full picture
Owned by nobody.
Owned by you, reluctantly.
Owned by you, emphatically.
Owned by your partner, explicitly.
§ III

Four things that make Bayview different.

Partner-led, by design
i.

Founder and business, as one file.

Most firms serve either the company or the owner. At the scale our clients operate, they are the same problem — and we plan for them as one.

ii.

One engagement, every jurisdiction.

A single partner owns your file end-to-end. Vetted local counsel in 40+ countries is coordinated on your behalf — never your project to manage.

iii.

Four credentials, always in the room.

Law, accounting, IRS representation, and financial planning. Every material question is answered by a qualified partner — never deferred.

iv.

Senior-only work.

No juniors learning on your return. Modern tooling handles reading and reconciliation; partners handle judgment.

Admitted
JD
Tax law & LL.M. · treaty opinions, controversy
Certified
CPA
Compliance & assurance · consolidations
Enrolled
EA
IRS representation · audit defence
Planning
CFP
Wealth across borders · family & estate
§ IV

What we handle.

Three pillars · one engagement
i.

The business.

  • Entity choice & treaty planning
  • GILTI / Subpart F / §962
  • Transfer pricing & PE risk
  • US & foreign compliance, packaged
  • Forms 5471 / 5472 / 8865 / 8858 / FBAR
ii.

The founder.

  • Pre-immigration & relocation planning
  • RSU / ISO / QSBS / 83(b) elections
  • Equity in multiple jurisdictions
  • Exit & liquidity events
  • Dual residency & treaty tie-breakers
iii.

The family.

  • Foreign grantor & non-grantor trusts
  • Global estate planning
  • Family office coordination
  • Generational transitions
  • Inbound investment structures
§ V

Where we practise.

San Francisco HQ · vetted local counsel abroad
Coverage

Headquartered on the Bay. We maintain working relationships with counsel in forty-plus jurisdictions — vetted personally, retained only when your file demands it.

40+
active jurisdictions
1
partner per engagement
LondonZurichDubaiHong KongTokyoSingaporeSão PauloMexico CitySan FranciscoHQ
— dashed lines indicate active partner jurisdictions —
§ VI

How an engagement runs.

Four steps · one partner throughout
01

Intake.

A note, a call, an NDA. We map every entity, jurisdiction, and asset class before the engagement letter is drafted.

02

Review.

We read every prior return, cap table, and trust instrument. Issues surface in days — not in the next billing cycle.

03

Partner memo.

A written opinion: the structure, the exposure, the playbook. Signed by a named partner — not by committee.

04

Ongoing.

All filings handled. Quarterly partner check-ins. Changes in law flagged proactively — in writing, with a recommendation.

§ VII

Case notes.

Anonymised · representative
Founder · US + CN + SG

They untangled a cap-table mess across three countries and saved us a mid-seven-figure tax hit on exit.

Founder, B2B SaaSExit · 2025
Family · UK → US

Pre-immigration plan, trust restructuring, year-one filings — all under a single engagement letter.

Family office principalRelocation · 2025
Owner · HK + US + CA

Bayview runs compliance in every jurisdiction we operate. One partner, one team, no surprises.

CEO, consumer goodsOngoing
§ VIII

Correspondence.

Read personally · one business day

Tell us what you’re working with.

A short note is sufficient: the situation, the jurisdictions involved, and a rough timeline. A partner will reply within one business day — with a scoped proposal, a recommended referral, or an honest note that this isn’t our specialty.

OfficeBayview Tax · San Francisco, California
By letter

Engagements by introduction or direct inquiry. All correspondence treated as privileged until scope is established.