INTERNATIONAL TAX

Experience-based Foreign Tax Insight

Our international tax attorneys understand that your business does not always stop at the border. We work with both domestic and foreign entities to structure cross-border transactions in a tax efficient manner and to facilitate tax-efficient global expansion. Our services include:

• Planning to minimize the effects of the FIRPTA, branch profits tax, and earnings stripping provisions of U.S. law.
• Structuring the foreign operations of U.S. businesses and individuals, which includes developing strategies to:
  • Minimize the effects of the controlled foreign corporation and passive foreign investment company rules, including strategies for entity structures and allocations of offshore activities to manage exposure to subpart F and GILTI inclusions.
  • Maximize the benefits of the foreign tax credit and domestic production activity income rules.
• Structuring multinational business groups and their transactions to minimize worldwide taxes.
• Advising multinational corporations on how to structure retirement and pension plans to maximize worldwide tax benefits.
• Providing planning and administrative services for U.S. residents with foreign holdings and foreign residents with property in the United States.
• Advising foreign governments on how to structure their tax systems to encourage investment and development and on U.S. tax changes that could affect their economic policies.

Individually Tailored Services for Our Individual Clients

Our group provides advice about income tax to U.S. residents who work for companies abroad and foreign residents who work for companies in the United States. As part of our services to individuals, our attorneys provide pre-immigration tax planning and outbound expatriation, including drafting and structuring foreign and domestic trusts and worldwide tax compliance.