INTERNATIONAL TAX

Our international tax attorneys advise clients with respect to the tax and legal issues related to structuring and implementing cross-border transactions, including the representation of nonresident investors acquiring interests in U.S. entities or real estate and U.S. business entering foreign markets through direct operations or joint ventures, foreign sales and distribution agreements or outsourcing arrangements.

INTERNATIONAL TAX EXPERIENCE

Our attorneys negotiate and document in-bound and out-bound transactions, and counsel clients in relation to the U.S. and foreign tax implications associated with such transactions. An international tax attorney from our group can assist you with:

  • Identifying and implementing tax-planning strategies to minimize worldwide tax liabilities
  • Analyzing and planning for the availability of tax treaty benefits
  • Planning and structuring in-bound or out-bound investments
  • Taxation of expatriate executives and business owners
  • International estate planning for non-residents of the United States
  • Analyzing choice of entity and domicile for companies entering new markets
  • Overseeing and managing local country tax compliance and US tax reporting requirements
  • Restructuring or reorganization of corporate ownership and multinational affiliated groups
  • Management and implementation of international special projects
  • Planning and implementing structures for international software and technology licensing
  • Advising clients on Foreign Investment in Real Property Tax Act
  • Advising clients on transfer pricing and adopting transfer pricing documentation
  • Tax planning for international debt and equity transactions with respect to income shifting and thin capitalization rules
  • Planning with respect to Subpart F Income and Controlled Foreign Corporations
  • Review of financial and tax products and projects

CROSS-BORDER COLLABORATIONS

We routinely collaborate with certified public accountants and chartered accountants domestically and internationally to render the best tax advice, taking into account both U.S. and foreign country tax rules. We work with our client’s existing tax advisers overseas, or help them vet or retain foreign tax advisers if they are not represented in the country in question.play 21 for