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Our advice is often sought when clients are in the process of creating, acquiring, or reorganizing U.S. and foreign entities. While we do not generally create legal entities, we provide U.S. tax advice on the appropriate U.S. or foreign entity to be created. Choosing the right legal entity can help minimize the worldwide effective tax rate.
Restructuring U.S. and foreign legal entities can result in U.S. taxable gains. However, it is often possible to restructure in a manner that qualifies the transactions as non-taxable under the U.S. tax code. We have extensive experience in this area.
We also provide U.S. tax advice on a variety of complex U.S. tax issues, including: subpart F income, controlled foreign corporations, outbound transfers, tax treaties, passive foreign investment companies, and much more.
U.S. tax laws are remarkably expansive and may apply to foreign transactions that would appear to have no U.S. connection. Due to the breadth of the U.S. tax laws, it is necessary for us to have a thorough understanding of our clients’ worldwide activities.
It is not unusual for us to provide a substantial amount of advice during the process of setting up or reorganizing cross-border operations, and then for our role to be much smaller on an ongoing basis.
We do not generally prepare U.S. tax returns, but we often provide a summary of U.S. tax filing requirements for our clients and their tax return preparers. Understanding the U.S. tax filing requirements is very important. Merely failing to disclose certain transactions or activities can result in substantial penalties.
We advise our clients on U.S. tax laws regarding cross-border transactions. We do not provide advice on the tax laws of other countries, but we often work in conjunction with non-U.S. tax advisors to craft multi-jurisdictional solutions that meet our clients’ goals.
Feel free to review the 500+ tax charts on our website.
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