GLOBAL TAX AND CORPORATE SERVICES FOR U.S. PARENT COMPANIES

  • Advice on the U.S. tax aspects of alternative forms for doing business abroad and choice of business form
  • Structuring cross-border mergers and acquisitions and joint ventures
  • Advice with respect to intercompany transactions
  • Advice with regard to financing foreign subsidiaries, including assistance in determining the best mix of debt, equity and “hybrid” instruments
  • Advice with regard to “passthrough” entities and “checking the box” on foreign entities
  • Strategies for minimizing the worldwide effective tax rate and increasing earnings after tax
  • Advice with respect to the tax aspects of the ownership and licensing of trademarks, patents and other intangibles
  • Advice regarding the accumulation of profits in foreign jurisdictions, as well as the tax cost (and opportunities) associated with repatriating the earnings to the United States
  • Alternative locations for foreign investment-tax and non-tax business considerations
  • Analysis of proposed changes to international tax laws
  • ecommerce-global tax advice