International Taxation

Tax Planning & Consulting Services
Our team provides professional tax planning and consulting services in connection with the following:

Businesses and Entities

• Optimization of structures for foreign investment and business operations in the U.S.
• Optimization of structures for U.S. investment and business operations outside of the U.S.
• Structuring for cross-border acquisitions, sales and other exchanges
• Structuring for acquisition, operation and disposition of U.S. real estate
• Controlled foreign corporation issues
• Interest Charge Domestic International Sales Corporations (IC-DISC’s)
• Passive Foreign Investment Company issues (PFIC's)

Individuals and Trusts

• U.S. executives working and residing overseas
• Foreign executives working and residing in the U.S.
• Tax issues for non-citizens immigrating to the U.S.
• Tax issues for individuals considering expatriation from the U.S.
• Gift, trust and estate considerations for non-citizens with U.S. based assets
• U.S. beneficiaries of foreign trusts

Other Matters

• Income tax treaties and totalization agreements
• Foreign tax credits
• Subpart F and other anti-avoidance rules
• Tax aspects of foreign currency exchange
• Matters related to payments of U.S. source income to foreign persons

Transfer Pricing
Our team works with multinational companies to define, manage and plan for transfer pricing. Our services include the preparation of domestic and worldwide documentation designed to comply with local requirements, assistance with the alignment of tax planning objectives and business objectives, and assistance with the assessment and management of tax risk.

Outsource International Tax Director Services for Companies and Global Families
Our team provides outsourced services to companies that can benefit from having a part-time international tax director.The need may be short term, such as in the event of an acquisition or disposition that temporarily increases workload beyond what can be comfortably handled by internal resources, or due to the need for a temporary replacement of a resource that is on vacation or other type of leave. Alternatively, the need may be long term due to a regular and continuous need for a sophisticated resource to assist with periodic international tax issues, but where the need requires less than full-time attention.

Our professionals provide hands-on services to help companies focus on international tax planning opportunities and compliance matters.Additionally, we can assist global families with the management of U.S. based investments, U.S. trust matters and overall financial planning objectives to meet their respective needs.

Withholding Tax Services
Our team provides advice to companies and individuals regarding issues related to withholding and reporting compliance, including:

• U.S. withholding and reporting for payments made to foreign persons
• Use of Qualified intermediaries
• Foreign withholding tax matters
• Application of income tax treaties to amounts subject to withholding at source
• Application of U.S. withholding rules to offshore withholding agents
• Backup withholding matters

Expatriate and Impatriate Tax Services
Our team provides tax planning and compliance services to U.S. executives on assignment overseas and their U.S. employers, as well as to foreign executives on assignment in the U.S. , including:

• Consultation to foreign nationals and U.S. citizens living abroad with the objective of providing solutions to minimize taxes worldwide, including through the application of income tax treaties and social security totalization agreements
• Preparation of U.S. income tax returns and other required filings for individuals with cross-border tax issues
• Consultation to companies with executives on overseas assignment (inbound/outbound), including assistance to human resource and payroll personnel
• Assistance with the calculation of gross-ups of foreign assignment allowances, tax equalization computations, and appropriate actual and theoretical withholdings

U.S. Tax Compliance
Our team provides a wide variety of tax compliance and preparation services related to foreign and international tax reporting, including:

• General compliance services for U.S. corporations and individuals with foreign based businesses and investments
• Preparation of and assistance with data gathering for U.S. international tax forms (1118, 5471, 8865, 8858, 5472, 1120-F)
• Quantitative services related to U.S. international tax calculations (foreign tax credit, Subpart F, section 956, earnings and profits)
• Accounting and tax preparation services for foreign nationals and foreign owned businesses
• Withholding tax returns for U.S. payers to foreign persons
• Assistance with U.S. individual tax identification numbers
• Income tax services for U.S. individuals with beneficial interests in foreign trusts
• Estate tax returns for nonresident aliens

IRS Matters
Our team provides support and representation services to taxpayers, partnering with the taxpayer and legal counsel, as appropriate, in connection with the following:

• IRS voluntary disclosures for U.S. persons with undisclosed foreign income and financial accounts
• Tax controversy, Competent Authority and other IRS matters