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Business Formation   -   International Expansion   -   Corporate Tax Planning

International and Domestic Tax Planning

We offer legal and tax counsel to business and corporate entities that are looking to expand into global markets. Our clients include US-based start-up companies in a growth phase looking to establish a presence in overseas markets, companies looking to market their products or services in international markets, and US-based companies looking to grow through acquisition.  

Our services center around in-depth knowledge of domestic and international tax laws, and we specialize in specific considerations for international expansion that include:

  • Determining whether a Permanent Establishment (PE) or Taxable Presence is created 

  • Income Tax Treaty Analysis and Planning

  • Choice of Entity, Entity Classification Analysis and Optimization of Structures for Business Operations and US Investment 

  • Structuring Interest Charge Domestic International Sales Corporation (IC-DISC)

International and Domestic Tax Compliance

We have extensive experience in helping companies with U.S. tax compliance of international operations. We offer professional counsel that addresses key issues including:

  • U.S. Disclosure and Reporting Requirements for International Entities:

    • Controlled Foreign Corporation (CFC) analysis and documentation

    • Passive Foreign Investment Company (PFIC) analysis and documentation

  • Assistance with Transfer Pricing documentation and Intercompany Agreements 

  • Assistance with Subpart F income, Global Intangible Low-Taxed Income (GILTI) and foreign tax credit planning 

Foreign Expansion into US

In addition to providing counsel to US-based companies geared for international expansion, we also offer guidance to international companies looking to expand into US markets by investment in US real estate properties, businesses, and other interests.

Similar to international expansion, companies looking to break into US markets will need assistance determining if Permanent Establishment is created, as well as ensuring compliance with necessary US reporting requirements for any US source income the company plans to receive. International companies will also need to consider appropriate choice of entity and optimal structures for US-based business operations.

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