Corporate International
Tax Services

• Comprehensive tax planning relating to hybrid instruments and entities, foreign tax credits, controlled foreign corporations, income tax treaties, branch profits tax, branch level interest tax, cross-border transactions, classification, withholding and location of intellectual property and holding companies
• Structuring of foreign investment in the United States and U.S. investments abroad
• Coordination and preparation of U.S. federal, state and local income tax returns for U.S. business entities with foreign owners, as well as foreign business entities operating in the United States, which includes information returns with regards to cross-border withholding, transactions with foreign related parties, foreign bank accounts, and U.S. ownership of foreign corporations and partnerships
• Transfer pricing studies
• Due diligence
• Use of tax holidays in foreign jurisdictions

Key Individual International
Tax Services

• Comprehensive tax planning, including the analysis of foreign tax credits, income tax treaties, foreign earned income exclusion, expatriation, residency elections and dual residency filing
• Pre and post residency planning
• Compensation planning to minimize U.S. income, payroll and Estate taxes
• Foreign Trusts, estates, foundations
• Coordination and preparation of U.S. federal, state and local income tax returns for both inpatriates and expatriates
• U.S. permanent residents living abroad
• Foreign nationals residing in the U.S.
• Foreign investments in the U.S.
• Pre-immigration and expatriation
• Voluntary disclosures
• U.S. international assignment services

Recipient of foreign gifts and inheritance