Many of our clients operate in non-U.S. jurisdictions. The complexity of the U.S. tax system is compounded by the intricacies of U.S. taxation of overseas operations. A simple flaw in the structure could lead to costly traps and may have unintended consequences. We work with our clients to find solutions for structuring transactions in ways that minimize the effective tax rate on a worldwide basis. Our International Tax Practice is very experienced in dealing with these complex rules.
Additionally, through our affiliation with HLB International, we have access to resources in most major cities throughout the U.S. and the world, helping us serve our clients with international operations. We work to ensure that our clients meet the tax compliance requirements while maximizing the tax benefits through proper planning and structuring. Our experience includes assisting companies outside of the U.S. to enter the U.S. markets as well as assisting U.S. companies in expanding their footprint globally.
- Application and use of the U.S.’s tax treaty network
- Cash/foreign earnings repatriation planning (e.g., earnings and profits, foreign tax credits)
- Cross-border financing and restructuring
- Foreign expansion (e.g., taxable presence in other jurisdictions, structuring)
- Overall global tax minimization (e.g., supply chain management, transfer pricing)
- Tax deferral planning (e.g., IP planning, minimization of anti-deferral regimes such as Subpart F)
Who We Serve
- U.S. Companies and Individuals Moving Overseas
- Foreign Companies and Individuals Moving into the U.S.