International Taxation

Overview

Today’s business and investment climate and the growth of cross border transactions mean more companies and individuals need tax specialists and accountants with a combination of global and local capabilities. Whether you are a U.S. company conducting business overseas, a foreign company with operations in the U.S., or an individual with global interests, we can help you design an efficient tax structure, guide you through increasingly difficult reporting requirements, help you attain your global objectives and maximize the growth of your business.

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We offer the required proactive advice and support through our own team of international tax experts and our global network of advisors. Our multinational tax service teams provide a wide range of opportunities for tax savings on both inbound and outbound investments and business. We also offer inpatriate and expatriate services to executives whose careers take them around the world. We also provide tax planning for income, gift and estate tax issues regarding international trusts.

These services include structuring offshore trusts and asset protection trusts, planning for U.S. beneficiaries, as well as ongoing planning and compliance advice to maximize the benefits of the structure. Global compliance, reporting and planning are more important than ever. We can help ensure you meet legal obligations, while increasing value, efficiency and control. Whatever your cross-border needs are, we can help find a solution that integrates with your strategy and meets your objectives. Our international tax experts can help you to remain competitive, maximize opportunities and to navigate the challenges in today’s global environment.

Corporate Inbound International Tax Assessment

Individual Inbound International Tax Assessment

Expertise

Services include:

U.S. International Tax
- Business
  - Choice of entity
  - Planning under anti-deferral taxes regimes
  - Multi-disciplinary advice for new market entry
  - Transfer pricing – including planning, controversy and risk management
  - Cross border transaction tax planning – including mergers, acquisitions, dispositions and restructuring
  - Repatriation planning and loss utilization
  - Export tax incentives
  - Supply chain and intellectual property planning
  - Global capital structure planning, cross-border finance, repatriation and cash access planning
- Private Client
  - Global income, estate and gift tax planning and compliance
  - Expatriate tax planning
  - Calculation of distributable net income from foreign trusts
  - Restructuring or decanting of foreign trusts to avoid deferred interest penalties
  - Individual income, gift and estate tax planning with cross-border philanthropy and tax compliance for private foundations with foreign investments and international grants
  - Puerto Rico bona fide residency
- General
  - Information reporting and withholding tax planning and compliance
  - Tax treaty interpretation and planning
  - Global effective tax rate and foreign tax credit planning
  - International tax reporting and compliance
  - U.S. and foreign advice coordination
  - Analysis of U.S. double tax treaties
  - Tax treaties
  - Inbound and outbound structuring
  - PFIC reporting