International Tax Law

Every international business transaction must provide for tax consequences likely to be encountered in at least two different countries – the country in which the party undertaking the international business transaction is domiciled and the country in which the international business transaction is undertaken.

The United States taxes international business transactions in accord with the requirements of the Internal Revenue Code, the Internal Revenue Regulations and a series of tax treaties that the United States has negotiated -- and continues to negotiate -- on an individual basis with various countries throughout the world.

Countries outside the United States tax international business transactions in accord with the requirements of their respective tax laws, tax regulations and individually negotiated country-specific tax treaties.

It is in fact the confluence of different countries’ separate tax regimes in international business transactions that makes the discipline of international tax law as complex, problematic and troublesome as it often tends to be. Nonetheless, the tax consequences of international business transactions need to be taken into account in the planning and execution of international business transactions, as failure to do so could quite possibly cause an otherwise- profitable business transaction to become a loosing proposition.

Some of the international tax services we provide include:

Advance Pricing Arrangements

Competent Authority Requests

Controlled Foreign Corporation (CFC) Counseling

Expatriate Tax Package Development

Foreign Tax Credit Counseling

Foreign Tax Credit Planning

Foreign Tax Law & Regulation Counseling

Foreign Tax Reporting Obligation Counseling

IRS Reporting Obligation Counseling

Passive Foreign Investment Company Counseling

Sub-Part F Income Counseling

Tax Incentive Programs for International Investment Counseling

Tax Incentive Programs for International Trade Counseling (formerly FSC Counseling and Extra-Territorial Income Counseling)

Tax Minimization in Establishing Foreign Operations

Tax Minimization in Ongoing International Business Operations

Tax Minimization in Liquidating International Business Operations

Tax Planning for International Business Operations

Tax Planning for International Business Transactions

Tax Planning for International Investments

Tax Planning for International Mergers & Acquisitions

Tax Planning for International Joint Ventures

Tax Treaty Applications

Tax Treaty Planning

Transfer Pricing Arrangements

Transfer Pricing Audit Preparation

Transfer Pricing Audit Representation

Transfer Pricing Issues

Value Added Tax Planning

Value Added Tax Refund Counseling

Withholding Tax Counseling

Withholding Tax Minimization