Tax Services for Foreign-Owned U.S. Companies and Non-Resident Investors

Tax Services for foreign-owned U.S. companies and non-resident investors
Advice on structuring U.S. investments, considering all alternative U.S. business forms ranging from start-ups to the acquisition of large U.S. target companies
Assessment of exposure to a U.S. "permanent establishment"
Review and analysis of foreign country taxation of U.S. investments
Financing U.S. investments, including advice with respect to capitalization, limitations on deductible interest expense, "conduit financing" arrangements and related matters
Advice with respect to intercompany transactions
Tax Treaty planning and "entitlement" to treaties
Tax aspects of U.S. real estate acquisitions and dispositions ("FIRPTA")
Tax planning for high net-worth international clients with U.S. assets and advice with respect to residency
Analysis of legislative proposals
U.S. Customs Services
U.S. Tax Compliance Services