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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, or when individuals are moving into or out of the U.S. If new entities are being formed, we can provide advice on the type of entity to be created. Tax planning is maximized by contacting us prior to taking any actions.
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 often work in conjunction with U.S. tax advisors and non-U.S. tax advisors. We can provide tax advisors summaries of the U.S. tax filing requirements with respect to cross-border activities, and/or we can review the international portions of U.S. tax returns. Understanding the U.S. tax filing requirements is very important -- merely failing to disclose certain cross-border transactions or activities can result in substantial penalties. If you are a U.S. tax professional with confidential tax return information, click here.
Feel free to review the more than 600 tax charts on our website.
Call today to schedule a meeting or phone consultation with Attorney Mitchel.
Ph. 860-767-4975
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