International Tax Advisory

Expanding internationally brings new opportunities—but also new tax challenges. We help U.S.-based businesses structure their global operations to stay compliant and tax-efficient from day one.

• Foreign Entity Structuring: Guidance on formation and classification of foreign corporations, partnerships, and branches for tax optimization and compliance, coordinating with a global network of affiliates to ensure that the structure factors in not only U.S. tax elements but also local jurisdiction considerations.

• Intellectual Property Planning: Structure and locate IP tax ownership in a way that balances tax benefits with operational and legal considerations.

• Permanent Establishment and Other Taxable Presence Analyses: Determine whether foreign activity creates a taxable presence under U.S. and foreign tax treaties and local law.

• Anti-Deferral Regime Planning: Navigate Subpart F, GILTI, PFIC, and other anti-deferral rules to manage U.S. tax on foreign earnings.

• FDII Deduction and IC-DISC Planning: Evaluate and implement export incentives to lower effective U.S. tax rates on sales, services, and royalties provided to non-U.S. recipients.
  
  
• Inversion and Section 367 Analyses: Assess the implication of cross-border structuring to avoid anti-abuse consequences such as inversions and Section 367 inclusions.

We help outbound businesses build tax-efficient international structures and stay ahead of evolving compliance requirements.

Entering the U.S. market requires more than just setting up shop. We help foreign businesses navigate federal, state, and local tax rules to structure operations and limit exposure.

• • U.S. Entity Structuring: Select the right legal entity classification for your U.S. operations—balancing liability, compliance, and tax impact.

• • Cross-Specialty Tax Coordination: Integrate income, sales & use, property tax, and credit & incentive planning into one cohesive U.S. strategy.

• • Withholding & Reporting Guidance: Ensure proper treatment of payments to foreign entities and compliance for all forms of income .

• • State & Local Nexus & Taxability Studies: Evaluate physical and economic nexus across U.S. jurisdictions and prepare for registration and filing obligations—while identifying opportunities related to state credits, incentives, and property tax exposure.
•  
  • Permanent Establishment & U.S. Trade or Business Exposure Analyses: Assess whether the parent company’s activities create a U.S. trade or business or permanent establishment, and implement strategies to ringfence liability and minimize cross-border tax risk.

With careful planning, foreign businesses can enter the U.S. market with confidence and a clear tax strategy.

We advise fund managers, real estate investors, and financial services firms on international tax strategies that protect returns and maintain compliance.

• PFIC Planning & Analysis: Identify and manage exposure to the the Passive Foreign Investment Company (PFIC) tax regime.
  
  
• Cross-Border Fund & Blocker Structuring: We design investment structures that account for investor profiles, treaty considerations, and operational goals—including blocker corporations to manage U.S. tax exposure for foreign and tax-exempt investors.
  
  
• Real Estate Tax Support: Provide structuring and reporting guidance for holding cross-border real estate investments, including structuring for FIRPTA issues.

Our tailored tax strategies help investors improve after-tax returns and meet cross-border obligations.

For companies with international operations, strategic planning can significantly reduce global effective tax rates. We help you take advantage of treaties, credits, and planning tools to maximize tax efficiency.

• Treaty Analysis & Application: Apply U.S. and foreign tax treaties to reduce or eliminate withholding and avoid excessive taxation.
  
  
• Withholding Tax Planning: Structure payments and contracts to manage withholding obligations and preserve cash flow, coordinating with our global network of affiliates to take into account local jurisdiction exemptions such as the parent-subsidiary directive and participation exemptions.
  
  
• Foreign Tax Credit Optimization: Maximize the availability of foreign tax credits to apply against foreign taxes not reduced under other methods.

We work with multinational businesses to align tax strategy with global operations—reducing friction across borders and supporting long-term growth.

Whether you’re a globally mobile executive, cross-border investor, or expatriate, we offer tax planning and reporting support tailored to your unique profile.

• Residency & Domicile Analysis: Review your tax residency and domicile and plan around complications with foreign tax liabilities & reporting, taking into account treaty availability and other mitigating factors where appropriate. We can also assist with nonresident pre-immigration planning for those moving to the U.S.
  
  
• Tax Minimization: Minimize excessive taxation through Foreign Tax Credits, Foreign Earned Income Exclusion, and related provisions.
  
  
• Foreign Trust & Estate Planning: Assist with structuring and reporting requirements for foreign trusts and estates.
  
  
• Employee Mobility & Hypotax Reviews: Review and advise on employee mobility issues such as permanent establishment concerns, equity compensation, and hypotax policies & calculations.
  
  
• Expatriation Returns: Advise on tax obligations and planning opportunities for those giving up U.S. citizenship or a green card.
  
  
• Foreign Asset Reporting: Ensure compliance with FBAR, FATCA, and other offshore reporting requirements.

We help globally connected individuals navigate complex international rules with confidence—mitigating risk, managing exposure, and ensuring full reporting compliance.