Global Tax Services for U.S. Parent Companies

Advice on the U.S. tax aspects of alternative forms for doing business abroad
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 U.S.
Alternative locations for foreign investment-tax and non-tax business considerations
Analysis of proposed changes to international tax laws
e-commerce-global tax advice
U.S. Tax Compliance Services