International Tax Planning and Compliance

Our firm’s international tax practitioners are widely recognized as thoughtful advisors, strategic thinkers and valuable business partners. Many of our multi-national clients have worked with us for many years as their companies have grown and evolved.

Tax Planning and Compliance

• Assessing the tax impact of currency fluctuations
• Branch terminations
• Federal, state and local tax compliance for US businesses with foreign owners
• FIRPTA withholding tax certificates
• Foreign corporations’ ownership of US companies and partnerships
• International debt equity strategies
• Subpart F income calculations

International Tax Consulting

• 338(g) elections for acquisitions of foreign corporations
• Assisting relocation to US under EB-5, L2, L-1 and other visa programs
• Branch profits
• Branch profits tax calculations
• CFC Consulting
• Change-in-accounting method to US dollars as the functional currency
• Compensation planning
• Corporate structures
• Due diligence for outbound and inbound transactions
• EB-5 project structuring
• Exchange controls and repatriation of capital and profits
• Expatriate tax services for employees
• Financing foreign operations
• FIRPTA planning
• Foreign earned income exclusion
• Foreign gifts and inheritance
• Foreign tax credits
• IC-DISC and export tax incentives
• Intellectual property holdings
• International Transactions
• Joint ventures with foreign partners
• Pre-immigration planning
• Preparation of estate plan including tax planning for international investors
• Preparation of treaty-based disclosures
• Residency elections and dual-residence filing
• Strategic planning, including issues such as choice of country or legal entity
• Tax planning for foreign trusts and estates
• Transactions with foreign related parties
• Transfer pricing benchmarking studies
• Transfer pricing documentation studies
• Using treaties to mitigate tax costs of cross-border transactions
• Wealth preservation projects

IRS Representation

Our tax professionals have significant experience representing clients in cross-border Internal Revenue Service (IRS) administrative proceedings. As the IRS expands its reach and the tax code becomes more complex, individuals and companies can inadvertently step into gray areas. International entities face even more complicated situations. Our team provides insight, guidance and representation.

• Application for employer ID for foreign corporations
• Application for Section 1446 relief – Certificates of Reduced Partnership Withholding
• Application for tax identification number for non-resident aliens
• Calculation of US withholding tax for payment by foreign persons
• Correspondence relative to FIRPTA withholding certificates
• Negotiation of central withholding tax agreements
• Preparation of applications for US tax clearance (residency certificates)
• Representation of foreign corporations and non-resident aliens in IRS examinations
• Representation of US-based multi-national companies in IRS examinations