International Taxation and Tax Compliance
Virtually every cross-border transaction or investment includes an international tax component. The firm undertakes strictly compliant international tax planning, primarily on behalf of commercial enterprises. Planning is customized and based on individual client goals and the features of specific transactions. It may involve accessing international tax treaties and/or advantageous provisions of domestic tax codes and regulations. The firm is also engaged in reviewing and revising historic international structures in order to bring them into compliance with current Internal Revenue Code requirements. Please note that the firm does not engage in domestic United States tax planning or in the preparation or filing of United Stated federal or state income tax returns.
Review and revision of defective and non-compliant trust and limited liability company structure designed by offshore promoter for holding fees due to U.S. fund manager clients.
Onshore migration of defective and non-compliant structure based on company limited by guaranty and having a share capital designed by previous advisor for holding securities and other assets for U.S. investor.
Representation of Dutch partner in Delaware partnership holding valuable intellectual property in a treaty-based claim for IRS refund of amounts improperly withheld by Dupont de Nemours from purchase price paid in order to acquire partnership interest.
Representation of various private foreign lenders in structuring of Internal Revenue Code compliant loans to U.S. borrowers, enabling tax efficient extraction of U.S. source portfolio interest.
Representation of French investors in structuring inbound investment into U.S. real estate sensitive to the Foreign Investment in Real Property Taxes Act.
Representation of Hong Kong trading company during inquiries made by Hong Kong Inland Revenue.
Representation of private and commercial clients in connection with reporting of foreign bank accounts on the Form TD F 90-221 (FBAR) to be filed with the U.S. Department of the Treasury.
Review and revision of defective and non-compliant trust and limited liability company structure designed by offshore promoter for U.S. fund manager clients.
Representation of foreign trustees regarding reporting requirements applicable to foreign trusts with U.S. assets, settlors and / or beneficiaries.