International Tax

International tax issues are no longer limited to big, multinational corporations.  Mid-size and small business now moves across borders, and with it comes a need for international tax advice.

  • “Inbound” Transactions: Foreign companies doing business in the U.S. need advice on permanent establishments, effectively connected income (ECI), U.S. withholding taxes, and “blocker” entities.
  • “Outbound” Transactions: U.S. companies doing business abroad need advice on foreign tax credits, controlled foreign corporations (CFCs), passive foreign investment companies (PFICs), and repatriating profits.
  • Immigration, foreign employment, and residency: Individuals working in foreign nations face a confusing array of tax questions. Which jurisdiction? Where to file? How much? When? Any special exemptions?
  • FATCA & FBAR: Making payments to and maintaining assets in foreign financial institutions and offshore entities is under increasing scrutiny by tax authorities. We help navigate the Foreign Account Tax Compliance Act, Foreign Bank Account Reporting, and other complex compliance responsibilities for international business.
  • Tax Treaties: Like no other area of tax law, international taxation is influenced by bilateral tax treaties that can minimize or eliminate the taxes a nation would otherwise impose on a business transaction.