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
- Choice of business form for doing business in the United States
- 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 ("limitation on benefits")
- 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 and advice regarding "first sale"
