International

International business is no longer just about multi-national corporations. High-growth and middle-market companies are routinely expanding operations and pursuing deals both into and out from the U.S.A.

• Cross-border mergers & acquisition

• Special tax-free reorganization issues, including potential inversions

• Controlled foreign corporations (CFCs), Subpart F income, and global intangible low-taxed income (GILTI)

• Passive foreign investment companies (PFICs)

• Effectively connected income (ECI) and tax return obligations

• Real estate investments and Foreign Investment in Real Property Tax Act (FIRPTA)

• Foreign Account Tax Compliance Act (FATCA)

• Representative offices

• Withholding taxes

• Immigration and expatriation tax planning for entrepreneurs, investors, and executives

• Tax treaties

• Transfer pricing