Cross-Border Activities and International Taxation
We provide tax and structuring advice to individuals and entities regarding their movement, investments and business activities that span international borders. We advise on determinations of and tax planning for the residence of individuals and companies within and outside the United States. We advise regarding issues arising under tax treaties and other international agreements including exchange of information, mutual agreement issues, and competent authority relief. We advise on matters of tax treaty residency and tie-breaker rules, permanent establishment, business profits, and general entitlement to tax treaty benefits, including limitation of benefits issues and foreign tax credit issues.We advise non-U.S. clients regarding U.S. tax issues affecting their inbound investments and business undertakings. We structure investment and business entities, joint ventures and parternships to optimize global income tax efficiency. We advise on tax issues relating to U.S. trade or business and effectively connected income, income classification and sourcing, U.S. real estate and FIRPTA, the branch profits tax, transfer pricing and interest stripping. We counsel non-U.S. persons on U.S. federal, state and local tax and reporting obligations and work with their accountants and international advisors to ensure proper reporting and coordination of advice and efforts.
We advise U.S. clients with cross-border operations and investments regarding the tax implications of and efficient structural planning for their activities. We advise on issues such as income characterization and sourcing, controlled foreign corporations (CFC), passive foreign investment companies (PFIC), foreign tax credits, transfer pricing and inversions. We provide counsel regarding tax issues unique to cross-border acquisitions, dispositions, reorganizations and other asset transfers. We advise U.S. clients regarding the myriad information and tax reporting obligations stemming from their international investments and activities and collaborate with their advisors around the world to coordinate the U.S. and non-U.S. tax issues affecting them.
We advise clients, including fiduciaries and other financial intermediaries, regarding their U.S. income tax withholding, reporting and related responsibilities. We counsel entities regarding their FATCA withholding and reporting obligations and devise comprehensive compliance plans and procedures.