Why do I need an International Tax Counsel?

To operate effectively in today’s global marketplace, organizations and individuals need international tax counsel that is fluent in the complexities of cross-border business.

An international Tax Counsel will:

• Assist clients in structuring cross-border investments and acquisitions, including development of holding company structures, selection of acquisition vehicles, repatriation and exit planning, and identification of relevant local law considerations.
• Advise corporate and individual investors and investment funds on all aspects of national income tax relevant to foreign investment, including choice of entity, Income Tax Treaties, foreign withholding taxes, foreign tax credit planning and the operation of national anti-deferral regimes.
• Guide non-national companies and individuals on the appropriate structures for inbound investment in various national businesses and real estate, and on national transfer pricing rules.
• Assist companies in developing cross-border equity and other compensation plans.
• Structure international joint ventures requiring coordination of tax results under multiple foreign jurisdictions.
• Assist with International Estate and Asset Protection Planning
• Setting up Foreign Corporations

An international Tax Counsel will assist in setting up foreign corporations because he knows that corporate law is not the same worldwide and concepts of entities otherwise known in the United States as a corporation can be quite different in other countries. The uses of foreign corporations are different with every case. Sometimes, the foreign corporation is used to conduct business in the foreign jurisdiction. An international Tax Counsel will guide you through many complex legal issues associated with it, such as:

• Double Taxation
• Income, Gift, and Estate taxation in the foreign jurisdiction.
• Protection for personal liability for the liabilities of the foreign corporation.
• Treaties with your country concerning operation of the business from a financing, accounting, tax, and legal perspective.
• Capital management in a foreign jurisdiction.
• Source of income rules.
• Controlled foreign corporations
• Subpart Income Tax Lawyers.
• Obtaining a credit for foreign taxes paid.
• International corporate reorganizations.
• Foreign trade.