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| Liechtenstein trusts are quietly becoming a legal gray-zone strategy for Americans seeking to sidestep global tax reporting under CRS in 2025. |
In 2025, as global tax transparency tightens under the Common Reporting Standard (CRS), high-net-worth Americans are quietly turning to a jurisdiction that’s not even on most tax advisors’ radar: Liechtenstein.
Why Liechtenstein?
Unlike most European jurisdictions, Liechtenstein maintains strict banking confidentiality and a unique “trust enterprise” legal structure that legally sidesteps many CRS requirements. As the U.S. is not a CRS participant, Americans using Liechtenstein structures benefit from a rare blind spot in global reporting.
How CRS Avoidance Is Structured
Typical structures involve setting up a Liechtenstein Foundation or Family Trust with layered beneficiary clauses. By leveraging a non-U.S. trustee and discretionary interest classification, many trusts are designed to avoid triggering CRS reporting on ultimate U.S. beneficiaries.
What the IRS Doesn’t See
As long as the trust is not directly tied to a U.S.-connected financial institution and follows Liechtenstein’s compliant but opaque structures, assets can legally remain outside U.S. and CRS visibility. However, this is a legal gray area — one that requires careful expert setup.
Related Wealth Protection Tactics
- How Offshore Trusts Protect Ultra-High Net Worth Assets
- Global Tax Optimization Strategies for Offshore Trusts in 2025
- How Wealthy Families Use Trusts to Avoid Probate and Preserve Legacy
Tools for Setting It Up
Forming a Liechtenstein trust structure typically requires coordination with offshore service providers. Consider vetted platforms like:
- doola – For forming compliant offshore entities
- StartGlobal – For international company setup
- Deel – For cross-border hiring through compliant structures
Legal Considerations
While Liechtenstein trusts can reduce exposure to CRS, they do not exempt you from FATCA or U.S. tax filing obligations. Americans must still report foreign accounts and entities via FBAR, Form 8938, and potentially Form 3520-A depending on trust structure.
The Bottom Line
Liechtenstein isn’t just for European royalty — it’s becoming the 2025 trust haven for strategic Americans who want to stay private, legal, and globally agile. But the structure must be precise. One mistake, and you’re flagged.
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